Prepared by Heloise Chicou, Regions4 and Teresa Garcia Perez, European Committee of the Regions | LGMA Adaptation Working Group Co-Leads
The Local Governments and Municipal Authorities (LGMA) Constituency welcomes the first draft as a workable basis for operationalising the Belém Adaptation Indicators, the Baku Adaptation Road Map and the tripling of adaptation finance. However, the draft fails to include local and subnational governments, despite their essential role in determining whether adaptation action is effectively implemented.
The summary of our position and our proposed amendments are set out in an accompanying track-changes version of the text that is being shared with negotiatiors.
Preamble: Recognising local and regional governments
- We welcome the recital recalling paragraph 10 of decision 12/CMA.7 on cross-cutting considerations and participatory, fully transparent approaches.
- We request explicit recognition of the essential role of local and subnational governments in planning, implementing, monitoring and financing adaptation, recalling paragraph 9 of decision 2/CMA.5 (action at all levels, from local to global) and paragraph 161 of decision 1/CMA.5 (inclusive, multilevel and cooperative action).
Belém–Addis Vision – Technical task force
- We welcome the proposed task force of 40 experts. Whichever composition option is adopted, it should include subnational expertise and provide for an independent nomination pathway.
- Parties should be invited to share experiences with subnationally disaggregated data and with engaging local and subnational governments and practitioners in testing the indicators.
Belém Adaptation Indicators
- The task force should specify the administrative scales at which each indicator can be disaggregated and provide guidance for Parties on drawing on data collected by local and subnational governments.
- The SB 66 feedback event should be open to local and subnational governments, Indigenous Peoples and local communities.
Baku Adaptation Road Map
- We welcome a dedicated workshop focused on means of implementation. It should address access to finance, technology and capacity-building for local and subnational governments to implement the targets at the local level.
- Non-party stakeholders, including local and subnational governments, should be able to submit views on workshop topics and participate meaningfully in the workshops.
Second global stocktake
- We ask that local and subnational adaptation progress and achievements be explicitly included, alongside the outcomes of the forthcoming IPCC Special Report on Climate Change and Cities, so that the contributions of local and regional governments are reflected in the assessment of collective progress.
Adaptation finance
- We welcome the focus on delivering the call to at least triple adaptation finance by 2035, which requires a defined baseline and a delivery pathway with interim milestones.
- Increased finance must translate into resources that subnational actors can access. We call for provisions on simplified access windows, enhanced direct access and support for locally led adaptation. We also call for finance provided to or channelled through local and subnational governments to be reported and tracked.
Proposals above build on the LGMA COP31 Guidance for Negotiators.

