NATIONAL ADAPTATION PROGRAMME OF ACTION (NAPA) – AN ASSESSMENT

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National Adaptation Programme of Action (NAPA) – Looking through the Lens of Rights









National Adaptation Programme of Action (NAPA) – An Assessment of Workers’ Rights



Nazmul Huq1

Department of Human Ecology

Vrije Universiteit Brussel,

Brussels, Belgium

E-mail: [email protected]



Jean Hugé

Department of Human Ecology

Vrije Universiteit Brussel,

Brussels, Belgium

E-mail: Jean.[email protected]



Abstract

Agriculture is the driving force of the economy of the Least Developing Countries (LDCs) and most of the workforce is involved in that sector. Climate change is the biggest threat to agriculture due to its vulnerability to climatic variability. Hence, the agrarian workforce is considered as the most vulnerable community to climate change impacts. Most LDCs developed their National Adaptation Programme of Action (NAPA) which is the interim strategy to adapt with the climate change. This paper examines National Adaptation Programme of Action (NAPA) of three Small Island Developing States (SIDS) to see how their NAPA policies react with agricultural workforce. The evaluations of the NAPAs are conducted assessed on three criteria: rights to participation, rights to livelihood and rights to alternative livelihoods. The findings shows that the NAPAs does not take agri-workers’ rights into account and do not valuate the role of agriculture sufficiently. The paper suggests some strategies that can be followed by the agricultural workforce can perform to adapt and mitigate the climate change impacts. The paper also suggests lobbying from the unions at national level for n integration of agri-workers as major stakeholders to deal with adaptation policies.



Key Words: Adaptation, Agriculture Labour, Climate Change Impact, Mitigation, NAPA



























1. Introduction

Small States Developing States (SIDs) are especially vulnerable to climate change vulnerabilities due to their geographic locations, limited resource base and due to the strong influence of the oceanic circulation system. Whereas no country is immune (World Bank, 2009) from the adverse impacts of climate change, SIDs show some additional vulnerability characteristics of climate change s their climate is influenced by large ocean-atmosphere interactions such as trade winds, El Niño and the monsoons (UNFCCC, 2007a). These climate characteristics, combined with their particular socioeconomic situations make SIDS, among which are 12 LDCs, some of the most vulnerable countries in the world to climate change (UNFCCC, 2007b). Sea level rising threatens their resource bases, especially the agricultural sector where much of their population is involved in. The United Nations framework Convention on Climate Change (UNFCCC) calls for an immediate adaptation action package called National Adaptation Programme of Action (NAPA)2 to climate change vulnerabilities realizing the facts that even if the best practices of mitigation action are deployed some of the impacts are unavoidable. NAPAs aim to develop of short and midterm adaptation plan consists of a series of tangible adaptation projects for the adaptation of the most vulnerable sectors.

The paper is a review of the consideration of the rights of agri-workers in the NAPA documents of 3 most climate vulnerable Small State Islands (SIDs) located in the Asian Pacific region. The names of the States are the Maldives, Vanuatu and Kiribati. The paper seeks to answer how NAPAs take environmental justice and rights towards agricultural labour into account. The consequences of climate change impacts hit the agriculture devastatingly as well as the workers involved in the sectors. The focus of the paper is to examine whether agricultural labour rights are considered in NAPAs, what protection mechanisms are deployed to save their livelihoods and what role the huge labour force can perform for mitigation and adaptation.



2. An Overview of National Adaptation Programme of Action (NAPA)

The NAPA is the configuration process of identifying immediate adaptation needs and actions. According to UNFCCC the NAPAs provide a process for LDCs to identify priority activities that respond to urgent and immediate needs with regard to adaptation to climate change (UNFCCC, 2009b). They defined the NAPA as following

National adaptation programmes of action (NAPAs) provide a process for Least Developed Countries (LDCs) to identify priority activities that respond to their urgent and immediate needs to adapt to climate change – those for which further delay would increase vulnerability and/or costs at a later stage. The NAPAs focus on urgent and immediate needs – those for which further delay could increase vulnerability or lead to increased costs at a later stage (UNFCCC, 2009a).

The back-story behind establishing NAPA has been initiated by the seventh Conference of the Parties to the UNFCCC that was held at Marrakech in 2001. The Marrakech Accords that emerged from this process included three funds relevant to adaptation. The Least Developed Countries Fund (LDCF) is one of them. It has been set up to support the 48 of the world’s poorest and most vulnerable nations in adapting to climate change impacts (Abdullah, Konate, Muyungi, & Reazuddin, 2009). The chronological evolution of the NAPA concept can be briefly listed as follows (UNFCCC, 2009a):

The NAPAs are expected to focus on the urgent and immediate needs for which further delay could increase vulnerability or lead to increased costs at a later stage. UNFCCC puts emphasis on using existing information for preparing NAPAs which will be action oriented, country-driven, flexible and based on national circumstances (UNFCCC, 2009c) unlike other national development plans such as Poverty Reduction Strategy Papers (PRSP).

To date, 42 NAPAs have been prepared and submitted to the UNFCCC secretariat and the remaining 6 are expected to be completed by 2010 (UNFCCC, 2009b). To date, 433 projects have been identified by NAPA and only four major categories occupy 80 percent of the total projects (UNFCCC, 2008) (UNFCCC, 2009b) (UNFCCC, 2009d). The largest (n=138) number of projects is in agriculture and food security followed by 78 water resources projects, 62 on terrestrial ecosystem and 50 on marine and coastal management. Besides, 45 projects have been identified for disaster management and early warning system, which is also a significant number (UNFCCC, 2009b). The estimated costs for the projects are USD 352 million for agriculture and food security, USD 837 million for water resources, USD 146 million for coastal zones and marine ecosystems and USD 133 million for terrestrial ecosystems (UNFCCC, 2009b). It has been estimated that the total required cost to implement all 433 projects is least USD 2 billion. This amount is required to implement the urgent and immediate needs to address the challenges of climate change in LDCs (Ibid).

The preparation of a NAPA is a systematic process. UNFCCC has defined several steps to make the NAPA democratic in nature, inclusive, participatory, action-oriented, country driven, and off course be responsive to climate change adaptation. According to UNFCCC guidelines (UNFCCC, 2009c) (UNFCCC, 2009d), following processes have to follow to prepare a NAPA:











In brief, above eight stages are followed to prepare a NAPA before submitting it to UNFCCC. As stated earlier, 42 countries have already submitted their NAPA to UNFCCC among which 138 projects belong to the agriculture and food security sector. This paper focuses on the agricultural sector and its related labour force . An analysis of the relevant documents reveals the major agricultural projects that have been identified by the submitted NAPAs. Among those projects, the following are most repeated (UNFCCC, 2009a) (UNFCCC, 2009d) (UNFCCC, 2009b) (UNFCCC, 2009c):





3. SIDS, Climate Change Impacts and Agriculture

The Small Island Developing States (SIDs) comprises 51 States and territories that are highly vulnerable to the effects of climate change and that are already feeling its impacts (UNFCCC, 2008). The projected impacts of climate change cross all sectors and the vulnerability and low adaptive capacity of SIDs is inextricably linked to the socio-cultural and economic context of these island States (UNFCCC, 2008). The Fourth Assessment Report (FAR) of the Intergovernmental Panel on Climate Change (IPCC) explores the key sectoral vulnerabilities and impacts. The report has firmly identified several impacts of climate change with very high and high confidence3. It states that (IPCC, 2007b)

Different studies also confirm the major sectoral vulnerabilities of SIDs. Water, agriculture and food security, health, terrestrial ecosystems and coastal zones are identified as most potential vulnerable sectors (UNFCCC, 2005) (IPCC, 2007b) (UNFCCC, 2008). It is very likely that due to the erratic behavior of climatic components agricultural production will face severe impacts such as short term crop failure and long term production decline (IFPRI, 2009) (Stern, 2006). According to the reports published by IFPRI (2009), and FAO (2004) thin markets, a lack of diversification in production, a high degree of economic openness, rapidly growing population, susceptibility to natural disasters, lack of economies of scale, remoteness, high transportation and communication costs and costly public administration and infrastructure may unlock the high exposure to agricultural and food insecurity of SIDs. Therefore, it can be concluded that the livelihoods of the numerous agricultural labour/workers will be seriously at stake unless necessary actions are taken urgently.



4. Climate Change and Rights

Although the climate change problems is already understood as both an environmental and development problem and increasingly also as an economic problem, the social and human rights dimension of climate change has been given very little attention (Aminzadeh, 2007). The issue of climate change can be framed as profound issue of rights. Climate change is seen as the biggest development threat (Klein & Persson, 2008) that will hamper the achievement of the Millennium Development Goals by 2015 (Oxfam International, 2007). From this point of view climate change is the biggest threat to establish human rights.

The International Labour Organization has 188 conventions on human rights where mostly employer rights have been emphasised (ILO, 2006). All the signatory countries are obliged to comply those entitled rights to the work force wherever deemed necessary. A human rights-based approach provides a conceptual framework for climate change policies; a framework which is normatively based on international human rights standards and which is practically directed to promoting and protecting human rights (HREOC, 2008). From this aspiration, the question is raised to which degree human rights (in this paper agricultural worker’ rights) are being protected in the decision making processes linked to tackling climate change.

5. Materials and Methods

The descriptive paper evaluates the rights of the agricultural labour force described in NAPA from three perspectives of rights. The analysis is broadly qualitative in nature and uses the available literature. The major difficulty that this research encounters is the lack of adequate literature on the climate change impacts and relation to workers’ rights. In the literature the link between climate change and rights is not much highlighted yet (Doussa, 2008) although climate change is considered a profound issue of human rights (Sinden, 2009). At the same time, the wide dimension of the human rights concept makes the research scoping difficult.

Dimension of Rights: The research has analysed NAPAs through the lens of agricultural workers’ rights in particular. In this paper three aspects of rights have been taken into account to evaluate the NAPAs. These are:



Selection of States: Three SIDs are selected for the evaluation. All three SIDs are located in the Asian and Pacific region, therefore this evaluation can be regarded as an Asian perspective. Those SIDs have prepared their NAPA and mostly their economy is based on agriculture and tourism. The three selected States are

Method of Analysis: For all the selected states the NAPA document has been consulted for identifying the projects they have prioritized. Subsequently, the projects are examined through the lenses of rights stated earlier. Furthermore (MoELAD, 2007), international labour standards, its convention and recommendation are also taken into account where applicable.

6. Results and Findsings

The Maldives

The Maldives is considered one of the most vulnerable countries due to climate change. The number of scientific and technical assessments undertaken in the country since 1987 has reiterated the need for long-term adaptation to climate change (MoEEW, 2007). In this connection, the Maldives submitted its NAPA to UNFCCC in 2007 indicating numbers of projects necessary for immediate adaptation action. Agriculture contributes 2.6% to its Gross Domestic Products (GDP) (MPND, 2006) and its food security is highly vulnerable due to excessive import dependency (MoEEW, 2007). In 2003, 7% of the population experienced food crisis and for nearly half of this population it lasted for less than 10 days (MPND, 2004). Despite all those scenarios, the document recognizes the agriculture sector as a less priority adaptation issue compared to tourism, fishing and health (MPND, 2006).

It’s a matter of great concern that through-out the NAPA process, neither the agriculture nor the involved labour forces receive adequate attention. In NAPA, it has been found that the Maldives has identified eight critical sectors which need immediate adaptation action. The agricultural sector has been placed fifth in ranking as it claims that public consultation placed Agricultural sector in fifth position. The public participation is an fundamental aspect of preparing NAPA but ironically only three consultation meetings have been conducted; one at national level and rest two meetings at regional level (MoEEW, 2007). For preparing a document which will be guiding document for interim adaptation action only three consultation meetings cannot provide the detailed insights of the vulnerabilities involved in different sectors. Moreover, the grassroots representation from agricultural communities in those meetings was none which is a straight violation of the “rights of participation” according to ILO convention no 135 concerning workers’ representation (ILO, 2006).

Under the eight identified critical sectors that need to be adapted urgently there are 51 strategic plans. Among those 51 strategic plans nine were dedicated to the agricultural sector but there is no indication on better livelihoods for the agricultural labour force, supports, or alternative livelihood options. All nine plans consist of highly ambitious agricultural development plans which would not be successful if there is a lack of skills in agricultural labour force. Ironically, skill development of the agri-labours remains out from the priority strategies.

Furthermore, when all the 51 priority strategies are narrowed down to 30, only one agricultural related plan takes place in that short list. The plan titled “introduce new technologies to increase local food production” is the only agricultural hint in the total list. There is nothing pertinent to agricultural development and enhancement of skills, efficiency, or training needs of the agrarian labours that supports 2.6% to the GDP. This negligence towards the agricultural labour force is contrary to the International Labour Standards of ILO Convention no 11 concerning the “Rights of Association and Combination of Agricultural Workers” (ILO, 2006). This negligence may provoke further vulnerabilities of the agrarian communities. Sometimes this phenomenon is identified as “adaptation risk” in climate related literature: indeed, imprudent adaptation actions may increase the vulnerabilities to the vulnerable people (Doussa, 2008) (UNEP, 2008).

The above brief analysis provides a glimpse on how agrarian communities are excluded from their entitled rights in the decision making process where they are one of the important stakeholder groups.



Vanuatu

Vanuatu is one of the most vulnerable States to the risks of climate change, climate variability and sea level rise ( NACCC, 2007) coupled with other natural disasters like drought, earthquake, landslide and coastal flooding. The livelihood and economy of Vanuatu are greatly shaped and driven by climate sensitive sectors. The effect of climate and sea level change are already very real and pose a tangible threat to the future socio-economic well-being of the country ( NACCC, 2007). According to the agricultural census of 2006, 80% of the total population of 209,920 lives in rural areas.

The economy of the country comprises a large smallholder subsistence agricultural sector (14.9% of the GDP) and a small monetized sector. Small-scale agriculture provides income for over 65% of the population while fishing, offshore financial services and tourism also contribute to the government revenues. The livelihood of rural people is dependent upon subsistence agriculture characterized by a very small domestic market. Fisheries, forestry and tourism sectors have also important contribution to the national economy.

Climate change is likely to impact on all sectors that are pertinent to the sustainable development of Vanuatu. The NAPA of Vanuatu has been developed in 2007 and a thorough analysis of this document can label it as a “pro-agricultural” document. It is praiseworthy that despite its lack of financial resources , the NAPA of Vanuatu shows enough courage to propose a project related to relocation of vulnerable communities. The NAPA has proposed adaptation strategies according to the provincial needs in its first stage of development. For all provinces the major focuses of the NAPA are on population resettlement, enhancing livelihood capitals through different initiatives i.e. structural and nonstructural, agricultural development, hazard mapping and developing micro-level adaptation plan etc. In its next stage, NAPA process involved selecting priority strategies for adaptation, using country identified ranking criteria4. Here NAPA through stakeholder consultation process was conducted in each of the provinces and priority strategies were listed down. This process results in 19 adaptation priority strategies among which 10 strategies are directly connected with agricultural and livelihood support such as relocation of vulnerable settlements and infrastructure, alternative fisheries, livestock and agriculture practices. This process includes capacity building, awareness rising, technology transfer and promotion of traditional knowledge as the core cross-cutting issues for all strategies ( NACCC, 2007).

The NAPA of Vanuatu again shows its agrarian closeness when priority strategies cut off to 11 instead of 19, as the impacts on livelihoods are considered key criteria for measuring the vulnerability. In this list agricultural development with the options of alternative agriculture, land-use management and re-location are placed in top. Finally 7 projects that have been submitted are just a readjustment of the previous 19 which were later again shortened to 11. In this seven projects agricultural and livelihood promotion and protection are given highest priority (Ibid).

A critical analysis of the NAPA of Vanuatu shows some positive components in terms of ensuring the rights of the work force involved in agriculture. As most of the projects are directly related to agricultural production, promotion and protection, implicitly the agri workforce is also part of the projects. This reality has been reflected through different initiatives throughout the NAPA process. Among others these are: the preservation and processing of agricultural products for better livelihood, the modernization of equipments, the use of traditional knowledge in agriculture, the promotion of rainwater harvesting etc. These are good signs in acknowledging the rights of the agriculture-based community. But rights to alternative livelihood supports are sidelined in the process and the term is not even included in the document. Furthermore, the process of participation is not such satisfactory as only 1 regional level consultation meeting has been conducted in each province, which is not very ambitious when it comes to participation. At the same time, relocation is an important aspect of the total adaptation procedure and the NAPA initially marked the item as important. But in the final stage, the relocation issue is incorporated neither as a cross-cutting issue nor as a pilot project. Though there has ample evidence that Vanuatu already started to relocate the vulnerable people. In conclusion, the NAPA of Vanuatu can be considered as a good start of adaptation action but through the lens of rights still some fundamental issue like participation and alternative livelihood support remain insufficiently considered.

Kiribati

Kiribati as a nation has been threatened by climate change; the people, their vital natural resources like underground water, food crops, and even infrastructure and their livelihoods have been threatened (START, 2006). Kiribati is a group of 33 coral atolls located very near to the equator in the northern Pacific Ocean. It comprises of three groups of islands - the Gilbert, Line and Phoenix Islands. 21 of these islands are inhabited and recently, the population was estimated at a little over 100,000 people (START, 2006) (World Bank, 2005). For the great majority, the livelihood is at the subsistence level, dependent heavily on natural environment resources. Subsistence and sustainable means of livelihood are based on indigenous tree crops, namely coconut tree, pandanus tree, bwabwai (giant taro), breadfruit and banana (MoELAD, 2007).

The NAPA developed by the government of Kiribati consists of nine projects. Though the countries’ economy is based on its natural resources and on subsistence agriculture, those sectors received very poor attention in its priority project list (MoELAD, 2007). It identified climate induced livelihood vulnerability e.g. decline of agricultural production and depletion of natural resources but surprisingly there is no hint of developing or protecting agricultural livelihoods from the adverse impacts of climate change. Not taking those vulnerabilities into account amounts to a deprivation of the rights of the workforce related to those sectors as well as the dependent communities. Similar to the Maldives case, this negligence may cause further climate vulnerabilities.

In the process of developing the NAPA, the responsible committee organized three consultation meetings which marginalized the vulnerable people. All the meetings were conducted with local elites, intergovernmental and local governmental officials identified 50 priority projects. This decision making process ultimately sidelined the marginalized opinions about the actual needs of adaptation priorities. The result is that form the very beginning of the NAPA process, grassroots people were deprived from their rights to participation. The top-down approach they followed for decision making is contradictory to the process of UNFCCC.

When the final nine projects have been finalized, according to the priority setting, the project “agriculture food crops development” is ranked in position six where major highlights are given on the development of a gene bank, promotion of agricultural products and cash crops and diversification of agriculture. All the sub-components of the project indicate a lack of consideration of the rights of the workers involved in agriculture. Without providing them the necessary support and developing their efficiency toward changing climate, agricultural diversification and promotion of agriculture will not be realized. Kiribati is by nature an import dependent country and its domestic market is very small in size (START, 2006). Being a net food importing country, one of the potential adaptation measures could be the enhancement of local production as well as expansion of local markets to support them.

The NAPA document of Kiribati is supposed to supplement the national development plan (NDS) of Kiribati for 2004-2007 (MoELAD, 2007). In reality, both documents are running in parallel from the very beginning. In NDS the enhancement of critical livelihood capitals and sustainable growth are considered as paramount objective but in NAPA those objectives are not considered. Thus the most threatening issue in the NAPA of Kiribati is not supporting the objectives of NDS and does not take the rights of the people who are at most risk due to climate change impacts into account.



7. Analysis of Findings

The above brief analysis of three SIDs’ NAPAs reveals a key fact: although there is NAPA for taking adaptation action, the preparation process shows important flaws.. The term livelihood development is a word which is rarely available in those documents. Besides, vulnerability and adverse impacts that would be felt by the huge labour-force involved in agricultural sector is not adequately considered. Being regarded as a key human rights issue, climate change should be the top of the concern of all vulnerable countries along with their population. At the same time it might be expected that secretariat of UNFCCC would take the issue of adaptation as a matter of survival. The FAR clearly concludes with that decisive finding that even if the most stringent effort is deployed to curb the emission temperature will rise for next few decades (UNDP, 2008). At this stage, rights of decent living and enough provision of livelihoods are the most important things that should be incorporated in any policy document related to reduce the adverse impact of climate change.

The countries which submitted NAPA or which are going to submit one are LDCs. Their economy is mostly dependent on agriculture. Therefore, any negative fluctuation of agricultural production may lead to the further aggravation of climatic disaster. The destruction of agri-based economies will bring untold livelihood collapse for the millions of work-force related to agriculture (Stern, 2006). The way climate change is happening so far, it is expected that if left unchecked all the LDCs will be devastatingly affected (World Bank, 2009).

Considering the facts, the secretariat of UNFCCC should put more emphasis to save the livelihood of agricultural related work-force. Again, retaining agri-biodiversity is another important factor for planetary survival (World Bank, 2009a). But, the paradox is among 138 NAPA projects under “agriculture and food security” very few take livelihood protection of agri-workers and the improvement of agro-biodiversity into account. Furthermore, the studied NAPAs have very few indications on enhancing endangered livelihood of vulnerable communities. Thus it is time to revisit the NAPA process, because so far its acknowledgement towards agricultural labour force in terms of their livelihood development is really insufficient.

Another important aspect to look at is that divergence of the major policy documents. All the major policy documents should be coherent in nature and adequate synergies should be open to meet the common goal. The contradiction is that policy documents like NAPA, PRSP and other national development plans rarely converge towards a single goal and radiates in different direction (Eriksen, Klein, Ulsrud, Næss, & O’Brien, 2007) (Prowse, Grist, & Sourang, 2009). UNFCCC and other development stakeholders should pay special attention to this issue.

As said earlier, climate change is an issue that can lead to the deprivation of the basic human rights. It has all the components to prevent human kind especially the poor and vulnerable communities to claim their entitled rights e.g. rights to live, rights to decent livelihood, rights to fair wage, rights to education etc. As a result, the government and international bodies have a moral and ethical obligation to do their best for protecting their rights. This commitment has been reiterated in several important international forums such as the Earth Summit 1992 and the World Summit for Sustainable Development in 2002, and more recently, in the Millennium Development Goals. Unfortunately, this commitment has not been reflected in the NAPA documents.



8. Role of Agricultural Work-force for Nationally Appropriated Mitigation Action (NAMA)

The possible instability caused by climate change could greatly affect the lives of workers and their families all around the world. While the connection between the consequences of climate change and the agricultural sector is the most obvious, it is important to realize that other sectors may also suffer due to climate change. Nationally Appropriate Mitigation Action (NAMA) is supported by the different convention articles. NAMA bears different meaning and actions for developed and developing countries. Article 4.7 states that “The priorities of developing countries are economic and social development and poverty eradication”. The clarification of the related articles demystifies the NAMA in context of developing countries. The NAMA should be developed in such a fashion which will ensure the following (Bratasida, 2008)




Those guidelines define some task for the related trade unions. In context of NAMA, Trade Unions can play vital role for mitigate the vulnerability of climate change. As stated earlier due to climate change the massive impacts on employment sector is inevitable. Therefore, the role of trade unions is much more important to mitigate the impacts as well as save the labour rights.








9. Conclusion

Climate change is the biggest threat for the sustainable development. The human development is profoundly threatened by the massive development of adverse impacts. Throughout the paper, it has been emphasized to focus on an issue which is not much touched; viewing NAPA from the view points of rights. It has been tried to explore whether human rights and labour rights are reflected throughout the NAPA process. The findings are not very much optimistic and seemingly NAPA process sidelines the issue of entitled human rights in NAPA process. It can be concluded that if NAPA marginalizes the human rights issue especially the employment rights issue the implementation of NAPA would be difficult and probably not sustainable. Thus it is an urgent call on the point of irreversible tipping points to shape the NAPA process in such a way which will ensure the rights of inclusion, participation, decision making, and finally rights to collective action to fight together against climate change impacts.























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1 Corresponding Author

2 UNFCCC 7th Conference of the Parties in 2001 requests to prepare NAPA for identify and implement immediate adaptation needs the Least Developed Countries according to its Decision 5/CP. 7, 28/ CP. 7 and 29/ CP. 7.

3 Confidence expresses the likelihood of occurrence. For very high confidence it is at least 9 out of 10 chances and for high confidence it is at least 8 out of 10 chances (for more information http://www.ipcc.ch/publications_and_data/ar4/wg1/en/tssts-2.html)

4 To know about the ranking criteria please visit unfccc.int/resource/docs/napa/vut01.pdf

5 For the definition of “green economy ”http://laborrightsblog.typepad.com/international_labor_right/2009/12/climate-change-copenhagen-and-workers.html


0 – HIGHLEVEL GLOBAL THEMATIC MEETING ON INTERNATIONAL
12 INTERNATIONAL MONETARY FUND FISCAL AFFAIRS DEPARTMENT
14 8BXXXE INTERNATIONAL TELECOMMUNICATION UNION RADIOCOMMUNICATION STUDY


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