On Day 3 of COP29, 13 November, Brazil submitted its updated Nationally Determined Contribution with a strong focus on multilevel governance and collaboration. While Brazil’s new commitment to reduce emissions by 59% to 67% by 2035, as compared to 2005, made headlines, the LGMA Constituency, and local and regional governments around the world, are paying attention to the how of the NDC – which strongly integrates Brazil’s subnational governments into the national plan and actions.

Brazil’s submission serves as an excellent example of how to scale up the role of local and other subnational governments in the planning and implementation of climate goals.

Brazil’s new NDC, which is the third updated NDC to be submitted in advance of the 2025 deadline, makes an explicit “Commitment to climate federalism between the union, states and municipalities,” with a direct reference to COP28’s Coalition for High Ambition Multilevel Partnerships (CHAMP) for Climate Action. Climate federalism translates into all levels of government working together, especially country, state and municipal levels. 

The submission is also a pioneering example that accelerates the implementation of para.161 of COP28 UAE decision, which urged Parties to adopt inclusive, multilevel, gender-responsive and cooperative action, language that is reflected in the main asks of the LGMA COP29 Joint Position.

The NDC says:

The federal entities will make coordinated efforts to tackle the climate emergency, including actions to prevent and prepare for extreme events, and will endeavor to integrate climate policy into their short-, medium- and long-term planning instruments, with a view to promoting greater consistency of climate action within the scope of their government planning. (Page 6)

Gregor Roberson, Special Envoy for Cities in CHAMP, said in a statement on LinkedIn, “Brazil’s leadership to prioritize partnerships with cities, states and regions to deliver climate action is a powerful example to the nearly 200 nations now writing their 10 year climate plans.”

Marjorie Kauffmann, State Secretary for Environment and Infrastructure, State of Rio Grande do Sul, Brazil and ICLEI Vice President congratulated her country’s submission. She said, “The NDC presented in advance and with an audacious target goes back to what Brazil wants to demonstrate as an example and, more than that, to practice within its means. So we understand that bringing in the target early and bringing in federalism is fundamental and will bring a gain in multilevel governance, which is the key to making public policies on climate change really work.”

How did we get to this NDC?

Brazil was one among the original endorsers of CHAMP at COP28. The initiative commits endorsing countries to enhance cooperation with their local, regional and other subnational governments – including cities, towns, states and regions – to collectively pursue efforts to limit the global temperature rise to 1.5 degrees above pre-industrial levels.

C40 Cities has been working closely with all levels of Brazilian government to advance the implementation of CHAMP. Co-Chair Mayor of Freetown Yvonne Aki-Sawyerr OBE said, “At a time when global climate leadership is in question, it is encouraging to see Brazil’s updated NDC put forward such a bold plan. The urban and subnational commitments are a powerful endorsement of the critical role cities and regions play in tackling the climate crisis, and how they can support the most vulnerable communities. By building on its CHAMP commitment, Brazil’s NDC recognises the importance of cities in addressing the climate emergency. C40 urges other nations to do the same.”

In June, Brazil’s association of cities Frente Nacional de Prefeitas e Prefeitos (FNP) announced a resolution on CHAMP at the ICLEI World Congress, in which mayors pledged their support for CHAMP and called for agility in structuring multilevel climate governance in Brazil. The letter also reaffirmed their commitment to acting jointly with state and federal governments in the execution and implementation of the climate agreements assumed by Brazil at international level.

Axel Schmidt Grael, Mayor, Municipality of Niterói, Brazil, is Vice President of FNP and chair of the Climate Action Support Portfolio for the ICLEI Global Executive Committee, played an instrumental role in bringing forward the CHAMP resolution. He was pleased with the new NDC submission, saying, “What Brazil has presented is an NDC that shows a lot of progress… Brazil is presenting the world with a series of goals that are important for our country and are ambitious.” 

Mayor Grael continued, “We have been discussing what we call “climate federalism” with the federal government, because the sub-national governments have a great contribution to make, as do civil society and the business sector, because we won’t have a savior of the country who will solve the climate problem. We will make the transition to a safer climate reality when society as a whole mobilizes. Local governments have an important role to play in this, so it is in this sense that I very much welcome what the Brazilian government has presented in this new NDC.”

Brazil’s NDC calls out the recent Commitment to Climate Federalism, Resolution No. 3

of the Federation Council, from July 3, 2024 and notes the importance of CHAMP: 

Building on the CHAMP Initiative (Coalition for High Ambition Multi-level Partnerships), endorsed at COP 28 by 62 countries. This instrument defines the climate agenda as a priority for the executive branches in government decisions at each level of government and sets out the commitment for federal entities to develop climate plans, instruments and targets, to be adopted in a continuous, progressive, coordinated and participatory manner with all relevant actors. (Page 6)

The LGMA has been an active supporter of CHAMP since COP28. Throughout the year, the Constituency coordinated new strategies and resources through the CHAMP Working Group, and built advocacy for CHAMP as a central strategy within the LGMA COP29 Joint Position.

In October, Yunus Arikan, focal point for the LGMA and Director of Global Advocacy for ICLEI,  and Gregor Roberson, Special Envoy for Cities in CHAMP, released a letter to the COP Troika – the Presidencies of COP28, COP29 and COP30 –  emphasizing that CHAMP offers a pathway to accelerate inclusive, multilevel climate action, mobilize financing, and align the climate and sustainable development agendas and calling on the COP Presidencies Troika to institutionalize subnational collaboration within the Paris Agreement framework.