Open Letter to the President-elect Nayib Bukele and his goverment team 2019-2024 presidential term.

OPEN LETTER TO THE PRESIDENT-ELECT NAYIB BUKELE AND HIS GOVERNMENT TEAM 2019-2024 PRESIDENTIAL TERM IN EL SALVADOR El Salvador Climate Change Roundtable with the purpose of contributing to make more effective the process of transition related to the environmental and climate change management, and considering that the current ecological crisis in the country has the potential to destabilize and make unviable any economic activation program, investment project, nation pact or social welfare plan that is promoted; raises the following considerations:

Current environmental and climate management approach:  The Salvadoran government has adopted and applied environmental and climate management under the "market environmentalism" approach, focusing on the commodification and privatization of nature through environmental compensation mechanisms promoted as climate, forests, ecosystems, landscapes, lands, biodiversity and water“friendly”. Such is the case of the Restoration and Reforestation of Ecosystems and Landscapes Program (PRREP); the National REDD-plusi Strategy; the Reform to the Special Law of Public-Private Partnership; the Environmental Compensation Funds; the proposed Special Economic Zone Law for the Eastern South Region of El Salvador and the Law for the Concession of Public Maritime Terrestrial Spaces; this stipulates that the concession enables individuals to replace the State to provide public service, use, exploit or exploit the territorial sea, its riverbank, “natural resources”, continental shelf, inland and inland waters-lakes, lagoons, reservoirs, rivers, bays, estuaries and coastal lagoonsii.  Market environmentalism and the "green economy" are promoted by the United Nations system of multilateral agencies, large conservation NGOs and governments of the countries that do not assume their responsibility in the face of global environmental problems and evade their international commitments. These actors have orchestrated policies based on the price of global natural commons, such as the carbon price policy (carbon taxes, carbon trading and carbon offsetting), REDD-plus being the most ineffective and iniquitous mechanism to mitigate climate change via the compensation of carbon emissions.  The extractive industries (coal, oil, gas, sand, gravel and biomass harvest) are responsible globally for 53% of carbon emissions and more than 80% of biodiversity lossiii. The fossil fuel extractive industries and the biofuels agribusinesses in addition to having a supply of low or zero cost-natural goods and to offer precarious labor, enjoy a wide and varied range of public subsidies, without which the referred industries would be unviable; hence, policies based on the carbon price are controversial and highly questionable.

Natural commons:  Both internationally and nationally, the mercantilist approach to environmental management in particular and to society and the economy in general, has activated the market for natural commons such as water, sea, land, territories, forests, seeds, atmosphere and biodiversity, and for intangible commons such as culture, knowledge, information and communication, and, science, technology and innovation -CTI-; restricting the population of free access to the referred commons and to decisions regarding the orientation, prioritization, benefits and risks of the CTI. That is the case of biotechnological, nanotechnological and cognotechnological applications such as precision 1

agriculture and aquaculture, transgenesis, cyber-agriculture, artificial intelligence, robotics and, bioenergy with carbon capture and storage.  The activation of the PRREP which is the flagship program of the Ministry of Environment and Natural Resources MARN-, responds to the genesis of an eco-laundering strategy to enable the REDD-plus mechanism within an adverse national and international environment, characterized at the time by a broad challenge to said mechanism.

With the PRREP serving as a cover for REDD-plus, the deaccumulation and dismantling of the national capacities required for effective environmental management has been hidden, as a result of its policy and management approach since 2009, centered almost exclusively on empowerment, appropriation and institutional mainstreaming of REDD-plus, to the detriment of a comprehensive, suitable, effective, appropriate and genuinely participatory environmental and climate policy.  The PRREP has applied "eco-laundering" camouflaging the extractivism of natural commons with green labels, and has managed a pseudo-inclusive discourse promoting the "inclusive management of ecosystems and landscapes" and applying clientelism with social actors. The MARN articulated the PRREP to the territorial management schemes of REDD-plus via the notion that it called "adaptation-based mitigation" -MbA- which lacks conceptual support and practical application, since REDD-plus is a compensation mechanism for emissions, its intrinsic logic prioritizes the activities with the greatest mitigation potential to the detriment of those with the greatest potential for climate adaptation.  In order for the MbA to have a reason to be, the logic of the REDD-plus mechanism would have to be reversed: it must make the activities with the greatest potential for adaptation prevail to the detriment of mitigation, which would distort the very purpose for which the referred mechanism was conceived under the Framework Convention´siv multilateral process. Amen that MARN has never promoted the development of studies of climatic impacts and their correlation in adaptation, which -in the logic of the MbA- would sustain the prevalence of adaptation within the framework of the PRREP and REDD-plus. The MbA has never been analyzed and much less validated by the international scientific community, nor has it been referred or formalized under the Framework Convention and the Paris Agreement´s multilateral process.  Contrary to what was disclosed by the promoters of REDD-plus, it does not encourage the protection or restoration of forests, ecosystems, biodiversity or lands, since by qualifying mono-specific forest plantations as forests according to the FAO definitionv they are eligible as organic carbon sinks to offset carbon emissions, which encourages the substitution of forests for plantations. Hence, REDD-plus is an eco-laundering mechanism to hide the extractivism and privatization of nature, since it does not eliminate or reduce emissions at the source, but it enables the extractive and polluting industries to increase their emissions, which can be offset by buying them emission compensation certificates via carbon trading or through actions or compensation funds for environmental damage which magnifies the risk of climate change.  In various regions of the planet, the REDD-plus territorial schemes are already causing division, violence, dispossession and land and territory hoarding; negatively affecting rural, coastal and indigenous communities, since within the framework of REDD-plus initiatives the principle of "free, prior and informed consent" has not been applied and the fundamental rights of the communities have been violated, favoring the expansion of monocultures -sugar cane, African palm and forest plantationsvi- exacerbating or provoking food insecurity, lack of access to lands, water and territories, loss of biodiversity, emigration and territorial depopulationvii. Although climate change and human rights are intrinsically related issues, climate finance does not apply criteria or guidelines in line with the human and mother Earth´ rights approach.  Although the synergy between the multilateral agreements on biodiversity, wetlands, climate change and combating desertification and drought is a genuine imperative for environmental sustainability, the "synergy" promoted for the achievement of the goals and the means of implementation of the SDG-15viii, the Paris Agreement and the Aichi Target 15ix, in practice sacrifices the objectives of biodiversity protection, land restoration and climatic adaptation, to achieve the goal of the Paris Agreement to reach the neutrality of the anthropogenic carbon in the 2

second half of the present century. Hence, the synergy becomes another mechanism for the eco-laundering of carbon pricing policies and the commodification of global and national natural commons.

Social Participation:  In El Salvador, the technical secretariat of the National Council for Environmental Sustainability and Vulnerability CONASAV- was officially placed in the hands of a group of agencies of the United Nations´ system and international cooperation entities, making it possible for them to intervene in the sovereign decisions of nationals and facilitating the insertion of their approaches, criteria and agendas -which respond to their institutional interests and to those of their financiers- in the processes and goals of the organization. Hence, the Plan El Salvador Sustentable lacks national vision, legitimacy and social viability, and is aligned with global agendas that protect the interests of extractive industries by eco-laundering its activities via "green markets and investments" and compensation schemes such as REDD-plus.

International Cooperation:  Although the country has had climate cooperation funds available for adaptation, mitigation and technology transfer in the Adaptation Fundx, GEFxi and Green Climate Fund; the MARN did not request them at the time, losing the opportunity to take advantage of these resources. During the last decade, MARN focused almost exclusively on mobilizing funds to co-finance the development and implementation of the National REDD-plus Strategy disguised under the PRREP and the National Plan for the Restoration and Reforestation of Ecosystems and Landscapes among others, and in order to mobilize funds it was articulated to the New York Declaration on Forests, the Bonn Challenge, SDG-15 and the International Decade for the Restoration of Ecosystems 2021-2030xii. In this line, in 2012, a loan to the IDBxiii for USD 200 million was negotiated to, among other actions, establish an Inter-ministerial Climate Change Committee functional to the National REDD-plus Strategy; and just after this loan was granted, 50% of the funds were reoriented -with the permission of the IDB- to other purposes unrelated to the issue of climate changexiv.

Loopholes, gaps and non-compliance legacy:  The current government through the MARN has been characterized by maintaining a very active profile in pushing a convergent agenda with the interests of the polluting countries, which evade their commitments with environmental compensation policies; for which the MARN has denatured the environmental policy and management by mobilizing the available capacities and resources almost exclusively in function of the activation of the REDD-plus mechanism. Worldwide, more than a decade of REDD-plus ineffectiveness for climate mitigation, environmental sustainability and respect for human rights makes its infeasibility increasingly imminent; which will show the failure of the Salvadoran government´s main stake, in detriment of the strengthening of comprehensive and effective climate and environmental action.  National capacities at the individual and institutional levels have not been strengthened and much less accumulated and consolidated in the central or municipal government entities, universities, research centers, NGOs, local communities nor relevant guild associations, in order to face the climatic challenges and assume the international commitments, among others, with regard to: a. Develop and update biennially -in the framework of an institutionalized national information system- the national inventories of greenhouse gas emissions by emitting sources and sectors required to: sustain technology needs, research, innovation, formal education and training to reduce emissions affecting environmental quality and contributing to climate change; and sustain a “national strategy for low carbon development” which should be officially notified by 2020xv. b. Monitor and apply the science of climate change to the national context, in order to be able to develop and update the climate change scenarios periodically for different areas of the country; and generate the parameters related to the climate change signal that should sustain the assessments on the current and future impacts of climate change in socioeconomic sectors, natural systems, territories, biodiversity and vulnerable human populations.

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c. Conceptualize, develop and implement strategies, policies and plans to adapt to climate change, based on climate change scenarios and impact assessments according to sector, natural system, territory or population prone to being affected. The foregoing in the context of the country's obligation to submit its National Contribution to the Paris Agreement every five years, including an adaptation component, which will be part of the National Communication on Adaptation to be compulsorily registered in an official public register and periodically examined in the framework of the first Global Balance by 2023 and then every five yearsxvi. The current government has relegated the action in climate adaptation, which is based on the precautionary principle stipulated in the Framework Convention, and has promoted the emergencist approach focused on compensating losses and damages as a response measure to the impacts of climate change. d. Design, institutionalize and put into operation a national monitoring, reporting and verification system of adaptation and mitigation actions, and of the support received; and periodically present the information generated to the Compliance Committee of the Paris Agreement, from which this obligation emanates. The information generated by the referred system will be transparent and freely accessible to facilitate the monitoring, participation and climate action of the relevant social actors.  Actions in territories with national and international status of protection and conservation of ecosystems and biodiversity such as Protected Natural Areas, Conservation Areas, Biosphere Reserves, Ramsar Sites and biological corridors, as well as the national and international legal framework that sustains them, have been relegated, confined and subordinated in the PRREP to the utilitarian and reductionist approach that gives prominence to the role of organic carbon sinks and reservoirs to offset carbon emissions, to the detriment of other fundamental ecological and environmental functions of terrestrial, freshwater, coastal and marine ecosystems. The previous, with the aim of obtaining public acceptance of the PRREP where the "carbon offset service" has been promoted as: restoration of ecosystems and landscapes, climate-smart agriculture, cyber agriculture, neutrality in land degradation, green urban corridors and cities, sustainable local development based on ecosystems, among others.

Call to President-elect Nayib Bukele and his government team:  It is imperative that the new government design and promote an effective environmental strategy to address the country's ecological crisis in the context of global climate change that threatens the continuity of life on Earth, which sustains and reorients the approach, priorities and guidelines of the current environmental and climate policy; in order to conserve natural diversity and look after the environmental sustainability of social and economic activity to ensure the current and future viability of the different territories of the country.  We ask that all instruments of environmental and climate policy -policies, programs, plans and projects- conceived and promoted during the last decade by the responsible government entities be abandoned and radically changed; which have not addressed, much less solved the ecological crisis of the country, by responding to utilitarian interests converging with the agendas of national and international pressure groups that protect the interests of extractive industries, polluters and predators, camouflaging environmental and climate damage with mechanisms of commodification of natural commons and environmental compensation schemes, as is the case of carbon pricing policies such as REDD-plus.  We exhort for the evaluation of the officials, directors and heads of technical units and members of the Technical Council of the MARN who have been responsible for the design and implementation of the policies and instruments of current environmental and climatic policy, as well as individuals designated as national focal points before the multilateral environmental agreements, whose negotiating positions and alliance policy are counterproductive to the country´s interests. The new public servants of the environmental field must have a suitable profile, for which they must have environmental awareness, sustainability vision, responsibility and social commitment, spirit of service and teamwork, and assume the public function with probity, honesty, transparency and inclusiveness.  We demand that the necessary corrective measures be taken to overcome the gaps, loopholes and breaches previously mentioned, in order to assume full compliance with the current national and international environmental 4

legal framework and the rule of law, whose non-observance could contravene the international human rights system. In that line, it should be encouraged deliberative citizen participation in the definition, application and evaluation of public policies to ensure their social legitimacy and political viability. i

Reducing emissions from deforestation and forest degradation in developing countries, and the role of conservation, sustainable management of forests, and enhancement of forest carbon stocks. ii According to the definitions stipulated in Art. 2 lit. a-k of the Law of Concession of Spaces of Maritime Terrestrial Public Domain. iii UNEP (2019): Global Resources Outlook 2019: Natural Resources for the Future We Want iv United Nations Framework Convention on Climate Change (1994), under which the Paris Agreement was adopted in 2015. v According to the FAO and the Paris Agreement, forest is defined as “lands that extend for more than 0.5 hectares with trees of a height greater than 5 m and a canopy cover greater than 10%, or trees capable of reaching this height in situ”. vi Such as plantations of timber species, fruit trees, coffee and cocoa which are being promoted under REDD-plus in El Salvador. vii World Rainforest Movement (https://wrm.org.uy/es/), REDD-Monitor (https://redd-monitor.org/) and the Global Forest Coalition (https://globalforestcoalition.org/es/) viii Sustainable Development Goal 15 under the 2030 Agenda related to biodiversity protection and combat desertification and draught. ix Aichi Target 15 is part of the Strategic Plan for Biodiversity 2011-2020 under the Convention on Biological Diversity. x This fund reserved at the time 4 million dollars for El Salvador, which were never mobilized by the government. xi Global Environment Facility. xii It aims to guide and support synergistic actions among the multilateral environmental agreements MEAs to comply with the SDGs, the Paris Agreement and the Aichi Target 15. xiii Inter American Development Bank xiv IDB´s loan ES-L1071: Integral Program for Fiscal Sustainability and Adaptation to Climate Change for El Salvador, ratified by the Legislative Assembly in 2012, and reoriented at 50% a few months later for other items and institutions as follows: more than $ 15 million for presidential house, more of $ 2 million for the National Institute of Sports of El Salvador, $ 25 million for the Treasury, $ 6 million for the Ministry of Defense, $ 34.2 million for the Ministry of Economy and 19.2 million for the Ministry of Public Works, Transport, Housing and Urban Development and the University of El Salvador. xv Which, as per the Paris Agreement, the Salvadoran State is obliged to officially notify it to the relevant secretariat under the referred Agreement. xvi The Paris Agreement establishes that under the Global Balances it will be determined the collective progress in fulfilling the long-term purpose and goals of the referred Agreement; and on the basis of the information notified by the countries, the measures adopted and the support provided/received in mitigation, adaptation and means of implementation such as technology, capacity building and financing, will be examined to update and strengthen them.

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Agentes de Cambio Alianza de Ulúas, Lencas y Nonualcos Asociación Biólogas Asociación GAIA El Salvador Asociación Salvadoreña de Energías Renovables (ASER) Centro Bartolomé de las Casas (CBC) Fundación Nacional para el Desarrollo (FUNDE) Centro de Investigación sobre Inversión y Comercio (CEICOM) Enlaces por la Sustentabilidad Universidad Francisco Gavidia (UFG) Fundación para el Desarrollo de la Cultura Indígena Los Pasos del Jaguar Movimiento de Unificación Indígena de Nahuizalco (MUINA) Organización Indígena Pueblo Nahuatl Pipil (OIPAN) Siglo XXIII: Paz Sustentable Solidaridad CVX Miembros expertos

With the support of:

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