Evolution of Transparency Reporting towards Effective Transition to Low Carbon Economy in Vietnam

The paper analyzed the evolution of policies to reduce GHG emissions reduction in Vietnam, primarily to fulfill its transparency commitment under the UNFCCC and the Paris Agreement. The uncertainty in the transparency rules of the Paris Agreement will be considered to sketch-out the most likely options for developing national policies to meet the future transparency requirements. The key actors and factors in Vietnam impacted by the policies are illustrated. To analyze the extent of penetration of transparency actions and future potentials provided these options, the progress of building congruence toward domesticating international norms of climate change in Vietnam by empirical assessment of the readiness to implement the ETF is conducted. In their turns, the way each relevant stakeholder responded to newly introduced requirements has a profound impact on policy making and enforcement in Vietnam and can represent a typical example of how the community react to a shift in transparency frameworks. Besides, the paper explores how the transparency policies will imply on the monitoring the transition to a low carbon economy in Vietnam under those reactions and the recommend the way forwards that the country may adopt to make its climate change commitment achieved and benefit http://www.scholink.org/ojs/index.php/se Sustainability in Environment Vol. 5, No. 3, 2020 51 Published by SCHOLINK INC. significantly from the process.


Introduction
Vietnam is one among 197 countries that are the parties to the United Nations Framework Convention on Climate Change (UNFCCC) with the aims of keeping a global temperature increase to well below 2 degrees Celsius and shifting to low carbon economy.
Transparency has traditionally been a key building block for the international regime to combat climate change and its impacts. The UNFCCC (Article 12 in accordance with Article 4) obliges all Parties to communicate to the Conference of the Parties (COP) information relevant to the implementation of the Convention, including in relation to emissions and removals (Notes 1, 2). The arrangements for national reporting have evolved throughout the history of the Convention, its Kyoto Protocol and most recently-the Paris Agreement (PA), into a more comprehensive measurement, reporting and verification (MRV) framework. The Modalities, Procedures and Guidelines (MPGs) adopted at COP24 in Katowice lay out rules for reporting and review under the Enhanced Transparency Framework (ETF) of the PA (Notes 3, 4). The ETF is a central component of the post-2020 international climate policy regime that will supersede the current transparency system under the UNFCCC in order to significantly enhance transparency for the reporting and review of information on parties' emissions, mitigation efforts, and support provided or received. Most importantly, it will underpin the dynamic process of updating nationally determined contributions (NDCs) and provide input to the global stock takes on successive five-year cycles. The ETF will apply to all Parties, with flexibility considering capacities of all parties.
Vietnam has been implementing different policies and activities to meet the transparency reporting obligations under the UNFCCC that are critical for building international trust and the domestic processes and capabilities needed to facilitate the transition to low-emission, climate-resilient development pathways. Like other developing countries, such a transparency system in place could facilitate implementation of mitigation actions via identifying areas requiring support. Furthermore, the greater transparency would help Vietnam jump start whatever carbon pricing instruments (either cap-and-trade or other regulatory approach) chosen to apply in the country to mitigate GHG emissions at a more economic efficiency to the society and enterprises.
Like most other developing countries, Vietnam faces challenges in complying with the requirements.
The most dominant challenges include lack of institutional and technical capacity, lack of political buy-in and supports from different actors in the system. However, among developing country Parties, Vietnam is one of the earliest to submit national reports, such its initial and second Biennial Update Reports (BURs) and the third National Communication http://www.scholink.org/ojs/index.php/se Sustainability in Environment Vol. 5, No. 3, 2020 52 Published by SCHOLINK INC.
(NC3) (Note 5). While the submission of the national reports is obliged under the UNFCCC, many developing country parties have not been able to do so in a timely manner. In this regard, the question often arise what enabled Vietnam to adhere to the requirement of the regime. Kawanishi et al., highlighted the institutional design of developing a national GHG inventory may have affected Vietnam's higher performance to respond to the international requirements (Note 6). Yet, a question remains on what factors have driven Vietnam to continue to accept such obligations for transparency in a proactive manner. Zimmer argued Vietnam's positive attitude in climate change in general has been promoted by co-benefits of climate change abatement, but not necessary focusing on the transparency issue. In this connection, the authors wish to build a hypothesis that the progress of "congruence building" between domestic conditions and international norms on transparency has influenced to facilitate positive attitude of Vietnam. Along with a series of international negotiation on the future climate change regime, one of key issues has been how to effectively engage developing country parties in global mitigation and transparency efforts, and for this reason, the framework for transparency under the UNFCCC has gradually developed by allowing flexibility for developing countries. On the other hand, countries like Vietnam, in partnership with development cooperation partners, developed domestic climate policy and strengthened a basis for positively responding such norms.
In this context, this study will first highlight the key milestones in evolving of the transparency reporting system internationally and nationally in Vietnam. Then it sketches out the vital gaps of the existing national MRV system to satisfy the MPGs. The uncertainty in the transparency rules of the PA will be considered when discussing the most likely options for the development of the suitable national policies, as the umbrella part of the multiple layers of the governance, through which norms related to the ETF under the PA are to be diffused.
The enhancement of the national MRV system will require a balance between the information Vietnam shall provide to meet the ETF requirement and the country's capability. Understanding the key actors in Vietnam that are highly impacted by the domestic transparency policies is important for an effective design and implementation of such policies. This paper highlights the key actors and assesses their readiness in moving toward a streamlined MRV system. In their turns, the way each relevant actor and factor respond to the effect of newly introduced transparency requirement has a profound impact on the enforcement of the policies and finally on the enhancement. The experience in introducing and effectiveness of implementing other reporting obligations is examined to predict the barriers and challenges for imposing the additional reporting requirement on GHGs at facility level. The suggestions are recommended to enhance the new regulations to satisfy the emerging ETF requirements but considering the country's capability.
Since 2012, Vietnam has been striving to low carbon economy by issuing the National Green Growth Strategy with the objective of "Green growth, as a means to achieve a low carbon economy and to enrich natural capital, will become the principal direction in sustainable economic development" (Note http://www.scholink.org/ojs/index.php/se Sustainability in Environment Vol. 5, No. 3, 2020 53 Published by SCHOLINK INC.

5).
In the light of the PA, how the domestic MRV system can spur the transition to a low carbon economy in Vietnam? The paper describes and explores how the monitoring for green growth should be part of domestic MRV system and how the enhancing of transparency policies under the ETF will imply on the monitoring the transition to a low carbon economy in Vietnam.
Finally, the paper will conclude the implications on the reporting policies design and implementation under the expected reactions from the impacted actors and recommend the way forwards that the country may adopt to make its climate change commitment achieved and benefit significantly from the process to the country, especially in pursuit of low carbon development.
As a theoretical background, this paper relies on the concept of congruence building in earlier literature with constructivist analysis. According to them, the readiness of domestic implementation of international norms crucially depends on congruence with key actors Stevenson, 2011;) (Note 7). Also, it is known the congruence has a variety in local context (Acharya, 2004) (Note 8). This paper shed a light on the congruence in the context of international norm on climate change transparency and Vietnam's domestic situation.

Evolution of Transparency Requirements under the UNFCCC
The UNFCCC provides the foundation for intergovernmental action to combat climate change and its impacts on humanity and ecosystems with the ultimate objective is to achieve stabilization of GHG concentrations "at a level that would prevent dangerous anthropogenic (human induced) interference with the climate system" (Note 9 action and support that is based on existing MRV framework set up under the UNFCCC (Note 3).
The new enhanced transparency framework consists of a common set of guidelines for all country Parties. This is a significant shift from the previous approach under the UNFCCC, which involved two separate guidelines for developed and developing countries and resulted in differing levels of quality of information.

Figure 1. Evolution of Transparency under the UNFCCC Regime
Source: revised from (Note 12). This "bifurcated system" of the ETF was elaborated as a results of compromise in the negotiation between the needs for establishing a common denominator for all parties to report the progress of mitigation actions and the challenge for many developing countries to undertake obligations despite limited capacity. By allowing flexibility for developing countries to gradually adjust the level of accuracy and details of reporting contents, the ETF demonstrated an enabling environment for congruence building from the development of norms, by demising the design of the system.
While the current MRV system requires developed countries and encourages developing nations to report climate action, the ETF requires all countries to do so every two years. As provided in the Table   1, the ETF introduced mandatory reporting items in addition to those required in the current transparency framework.
At COP 24 in Katowice, the transparency framework that is guided by the Modalities, Procedures and Guidelines (MPGs) was agreed (Note 3). COP 24 decided that the parties to the Agreement must follow the MPGs when reporting their annual GHG inventory under the UNFCCC, and "may" follow the MPGs when reporting overlapping information required by the two treaties in their NCs (Note 4).
MPGs will supersede the existing MRV systems established under the Cancun Agreement. MPGs stipulates that all countries (except Least Developed Countries (LDC) and Small Island Developed States) are required to submit reports and information every two years. At the same time, the current international assessments and reviews and the international consultation and analysis process will be replaced by technical expert reviews and facilitative multilateral consideration of progress on support, implementation and achievement of NDCs (Note 4).
The parties to the PA are to follow these MPGs starting with the first Biennial Transparency Reports  The ETF indicates that flexibility in the implementation of the Transparency Framework would be provided "to those developing country Parties that need it in the light of their capacities" (Note 4). The use of flexibility affects the type, quantity, frequency, and accuracy of information that is ultimately provided by Parties. While the PA does not specify how a need for flexibility is to be determined, the MPGs provide that such need is to be determined by a developing country itself. To reduce the risk of an abusive reliance on flexibility, the MPGs also require those countries that need it should clearly indicate the provision to which flexibility is applied, clarify capacity constraints, and provide estimated time frames by which the constraints will be addressed (Note 14).
At COP25 in Madrid 2019, the remaining elements of the PA's enhanced transparency framework have been agreed, including: formulating Common Reporting Tables (CRTs) and Common Tabular Formats (CTFs) that Parties must use in reporting information; agreeing the outlines of BTR, NIRs and Technical Expert Review (TER) reports; and designing a training programme for the technical experts in the TER process. The entire packages of these elements are expected to be adopted at COP26 (Note 15).
The effectiveness of the PA rests in the transparency system, since the Agreement has been designed to be a non-adversarial and non-punitive manner so that parties voluntarily pledge their commitment ex ante, and report progress of achievement ex post, This is a reflection of extremely complicated situation of the climate negotiation in Paris, in particular, for ensuring active participation by developing country parties, while many of them had expressed their concerns regarding their readiness to undertake a reporting obligation under the ETF. Such a strong voice became a driving force for a consideration for a balance agreement and demising the ETH by allowing different levels of accuracy with a view to gradual improvement of developing country parties. Thus, establishing and enhancing a national MRV system that will, in its turn, enhance and guide the NDCs is required for all parties under the Article 13 of the PA. The role of MRV is enhancing transparency of climate actions will remain as the core component of the PA. For developing countries, including Vietnam, the lack of robust MRV systems represents technical, technological, and financial challenges, as the country enters quantitative and legally binding commitments to reduce their GHG emissions committed under their NDCs. In other words, it can be said that the bifurcation has taken place as an important element of congruence, which was intended to fill the significant gap of their participation to a common and single transparency system. One may say this flexibility by designing the bifurcated system removed one of significant barriers towards the domestication of the norms under the ETF in developing countries, including Vietnam.

The Evolution of the Transparency Reporting System in Vietnam
Vietnam's transparency journey and commitment have been started since the preparation for the first NC in 1994, which was submitted in 2003. Figure 3 shows GHG emissions of Vietnam in the past and projection until 2030.

Existing National MRV System and Practice
To date, Vietnam has completed five inventories, included in three NCs and two BURs submitted to the UNFCCC to meet the existing reporting requirements for non-Annex I Parties (developing countries, like Vietnam). With the submission of the NC2 in 2010, Vietnam accelerated its pace, with submission of the BUR 1 in 2014, BUR2 in 2017, and the NC3 in 2019. As mentioned above, a question often arises why the submission of these reports after 2010 became so frequent, while many other countries have continued to take more time. According to the earlier constructivist discussion, it may be a case that a "norm-taker" (Checkel, 1998) (Note 16) has successfully built congruence between international norm set by the UNFCCC and the domestic governance structure in Vietnam, and the international norm has been diffused.  In order to clarify this hypothesis, at first, the authors wish to shed a light on a historical development of the institutional arrangement of the national MRV system in Vietnam.
The main domestic set up for the national MRV system are initially prescribed in the national GHG The Decision 2359/QD-TTg is, to date, probably the most important legal document that formulates and describes the system to fulfil the UNFCCC requirement on reporting GHG inventory. The implementation plan for the periodic national GHG inventory as regulated by the Decision is described in Figure 5 below.  discussion for GHG inventory development is relatively limited.
So far, Vietnam has gone through pre-2020 arrangement, made by the Cancun Agreement. In order to respond to the ETF introduced by the PA, Vietnam needs to further domesticate guidance to be issued by the UNFCCC. One significant difference between pre and post 2020 arrangements is that the government has pledged NDC as a commitment under the PA. Such a commitment will be implemented by mitigation efforts by respective sectors. For tracking the progress of implementing the commitment via the ETF, it will be necessary for Vietnam to have more in-depth involvement of line ministries. In this regard, the MONRE, as a norm-taker, is expected to increase its efforts to diffuse the international norms widely among relevant line ministries.
After signing the PA, the Decision of the Prime Minister No. 2053/QD-TTg (Note 17) was issued to specify the tasks in the Implementation Plan of the PA that are related to GHG inventories, as described in Table 1.  There are bold remarks concluded from the current state of national activities and regulations to fulfil the transparency requirement: -The current GHG inventory practices in Vietnam, based on the inventory years mentioned above, show no periodical frequency but were more conducted on an ad-hoc basis. -The current practices in the latest inventory follow 1996 IPCC Guidelines, except for the IPPU sector ("applying 2006 IPCC Guidelines"), and Tier 1 is commonly applied for almost all sectors except for two sub-sectors in the agricultural sector (manure management and rice cultivation), and two sub-sectors in the LULUCF sector (forest land and crop land).
-According to the Implementation Plan in 2016, Vietnam has to carry out a GHG inventory every two years in order to meet the requirements of the PA, as well as serve the periodic global stock take and already set up the transparency system (MRV) but is not in place yet in 2020.
3.2 Assessment of the Readiness to Implement the ETF at the National Level The primary objective of a national MRV system is to report on the BTR progress of domestic efforts under those indicators set in the NDC. Vietnam will use its MRV system to report tracked progress towards the achievement of its NDC, as well as related actions as defined in the national, sectoral policies, and strategies, and efforts for continuous improvement. The MRV system arrangement should also be able to report participation in international market mechanisms under Article 6 and the associated transfers of Internationally Transferred Mitigation Outcomes (ITMOs), according to Paris Agreement rules and guidance.
To submit the first BTR by the end of 2024 as regulated under the ETF, the existing domestic MRV system of Vietnam must be enhanced and, if necessary, re-structured.
The country's experience with the current reporting mechanism under the UNFCCC and the plan for implementing the PA revealed that Vietnam already faced challenges in complying with the existing requirements not mentioning yet the new reporting requirements under the future ETF. The existing issues are the lack of valid data to feed into the current system and the capacity to evaluate and analyse the data accordingly to the requirement of the UNFCCC.
The national regulation is available to create a national legal framework to address the reporting requirement to a certain aspect (focusing on GHG inventory mainly). In fact, there are several gaps to meet the ETF requirements that should be addressed further domestically and with international supports. We sketch out the key gaps to meet the new and emerging reporting requirements under the future BTR based on the latest reporting information in BUR 2.
At the national level, expected normative diffusion provided by the ETF are suggested as below.
The primary objective of a national MRV system is to report on the BTR progress of domestic efforts under those indicators set in the NDC. Vietnam will use its MRV system to report tracked progress towards the achievement of its NDC, as well as related actions as defined in the national, sectoral policies, and strategies, and efforts for continuous improvement. The MRV system arrangement should also be able to report participation in international market mechanisms under Article 6 and the associated transfers of Internationally Transferred Mitigation Outcomes (ITMOs), according to Paris Agreement rules and guidance.
To submit the first BTR by the end of 2024 as regulated under the ETF, the existing domestic MRV system of Vietnam must be enhanced and, if necessary, re-structured. issues are the lack of valid data to feed into the current system and the capacity to evaluate and analyse the data accordingly to the requirement of the UNFCCC.
The national regulation is available to create a national legal framework to address the reporting requirement to a certain aspect (focusing on GHG inventory mainly). In fact, there are several gaps to meet the ETF requirements that should be addressed further domestically and with international supports. We sketch out the key gaps to meet the new and emerging reporting requirements under the future BTR based on the latest reporting information in BUR. For the national GHG inventory specifically, the needs for enhancement of the current MRV system to bridge the gaps to meet ETF requirements are quite substantial as summarized in Table 2.  The latest national GHG inventory demonstrated that the gaps towards progressive ETF reporting are quite substantial across all five sectors. Until the submission of the first BTR by 2024 which offers more stringent in the BUR, the emerging needs to address the gaps and adapt to new ways of reporting things to create a robust MRV system become more urgent for Vietnam.
Considering the above gaps, it is important to strike a balance between the information Vietnam shall provide to meet the ETF requirement and the country's capability. The flexibility clause in the implementation of the ETF is granted to those developing countries (applicable to Vietnam as well) that need it in light of their capacities and flexibility can be provided in areas such as the scope, frequency and level of reporting. The interpretation of "flexibility" is still varied among Parties.
Hence, a high priority task to implement the ETF in Vietnam is to define on how, to what extent and areas the "flexibility" option should be applied to improve the country's reports from one submission to the next but at the pace suitable to the national circumstance. As argued in earlier scholarship discussions (Acharya, 2004) (Note 8), localization of international norms has a range of responses, in evolutionary and path-dependent forms. Therefore, the interpretation of this flexibility may allow some margin for Vietnam, and the MONRE may also play a role of agent to provide an effective and realistic interpretation, which is suitable to the Vietnamese governance context.
At sectoral level, the governance system of Vietnam gives the responsibility to manage the economic sectors to the five line ministries. The MOIT is for energy and industrial processes, the MARD is for agriculture and LULUCF, the MOT is for energy use in transport, the MOC is for energy use in building and construction works. The MONRE is now sharing the responsibility on waste management with the MOC despite the role is not entirely clear between the two. The MONRE, however, assume the critical role of compiling all the reporting requirement by the UNFCCC as assigned by the Government and facing various issues due to is capacity and resources to fulfil such responsibility.
The obligation to the ETF therefore also places on those line ministries. Consultation shows the line ministries are willing to, and in their respective authority, eager to implement such inventory and MRV works to gain more data and information from those they manage. What they need is the legal foundation for such work and substantial works to improve their capacity.

The Readiness of Key Actors in Meeting in a Streamlined National MRV System under the PA
To provide more insights for building on the country's capabilities to report under the ETF, we further examine the readiness of key actors in moving toward a streamlined national MRV system to build the country's accountability under the PA. The norms provided the ETF should be diffused through multiple layers of the domestic governance.

MRV for Sectors and Provinces
Under   The key actors at the sectoral and provincial levels listed in Figure 5 have been making an effort to fulfil the data requirements for the national GHG inventory system. For data from the sectors, line ministries in charge of respective sectors will provide data. As shown in Figure 7, local government (provincial and city's people's committee) will collect and submit waste related data.
The level of effort might, however, be different from ministry to ministry, and at the ministerial level from the provincial level. The roles and performance of GSO in the current scheme is mainly to receive of data reported from these key actors but the analysis is performed by the MONRE.

MRV at Facility Level
Currently there no requirement at a facility level for the national GHG inventory in particular and MRV systems in general under the existing MRV legal framework. All the inventories so far have been conducted top-down to the sectoral level only.
The enhancement requirement to apply higher tier methods to the key categories and to track the NDC's targets in Vietnam entails the need to involve and to regulate GHG emissions at a facility level, or in other words, imposing an additional reporting requirement on them. At this level, reporting responsibility will come along with the obligation to implement GHG inventory that would lead to the http://www.scholink.org/ojs/index.php/se Sustainability in Environment Vol. 5, No. 3, 2020 66 Published by SCHOLINK INC. government imposes the target for GHG emission reduction to the facility accordingly to an implementation roadmap appropriate to various sectors.
In the early stage of implementing the ETF in Vietnam, it is certainly that not all entities emitting  To understand the impacts on entities at the facility level and their readiness in complying with the new regulation, we examine the emerging challenges on them from the proposed MRV regulation by comparing these obligations with those from current regulations and with common practice on board.
In the early stage of implementing ETF in Vietnam, it is certainly that not all entities emitting GHGs will be targeted under the new reporting requirement but only the facilities which are defined as major energy users regulated under the Law on Energy Efficiency and Conservation. Vietnam. These DEUs account for about 30% of the total energy consumption in Vietnam (Note 20).
Recently in the Legal Document No. 10075/BCT-TKNL, the MOIT regulated on the reporting scheme of energy use, energy performance standards and updates the list of DEUs and requested the report is conducted online via http://dataenergy.vn annually on 01 February at the latest (Note 25). In the latest interviews with experts from line ministries, People's Committee and energy consultants, there is concern over the quality of data reported since it is considered as sensitive data of DEUs in relation with tax reports. The energy cost constitutes the product costs and then revenue of a DEU, the report on energy consumption and costs of a DEU to serve different reporting purposes may not bring the benefits but disadvantages in the view of a DEU. Therefore, the motivation of DEUs to report energy consumption data, especially ensuring the accuracy of data is not strong enough. To whom it reports to and the frequency of the report depend on what is committed to in the submitted and/or endorsed Environmental Impact Assessment report or Environmental Protection Commitment.
For the first step of regulating GHG emission at a facility level, a legislative reporting obligation for MRV of GHG emissions from DEUs shall be established as part of the national system. DEUs would thereby be obliged to monitor parameters related to GHG emissions as regulated in the methodologies accepted/approved under the national MRV system. The monitored parameters would need to be verified and different indicators based on these parameters would have to be reported on an annual basis.
The most challenge post issuance is to guarantee for an effective enforcement, especially when it comes with new reporting burdens on the targeted facilities. The penalties sanctions for non-compliance of legal documents in general are relatively weak in Vietnam. In the view of these facilities, they will consider the compliance if only the entailed cost (including penalty cost) is overweighed the benefit factor.
Obviously, complying with this new requirement will lead to additional administrative costs for the owners/operators of DEUs, whose impacts vary depending on sectors. Nonetheless, the size of the impacts can be certainly reduced if the new reporting scheme can be combined with the existing http://www.scholink.org/ojs/index.php/se Sustainability in Environment Vol. 5, No. 3, 2020 68 Published by SCHOLINK INC.
systems that are already established at the DEUs.
The existing system for the collection of energy consumption data from DEUs should be considered for utilization and integration when the MRV system is enhanced to cover the data collection from facilities for future. In this case, the existing forms should be revised to integrate GHG emission data to avoid the overlapping/duplication of work and reduce the cost for reporting entities.
The integration of the national MRV system with the existing reporting systems, especially on energy can be considered on two counts, as follows: • The existing monitoring and reporting procedure could be enhanced to convert the units of data for the sector.

Transparency through Domestic and International Carbon Market Mechanism as an Enabling
Factor Participating in international/domestic carbon market-based mechanisms is one of the rewards and motivations for GHG data report at a facility level. Detailed facility-level data that are increasingly collected for tracking the progress of NDC's target can be utilized for the MRV system for carbon This packaged support provides data gap analysis and recommendations on inventory guidelines and requirements and develop an action plan to align the national GHG emission inventory with IPCC and national guidelines and requirements on market-based carbon pricing. In parallel, it also identifies the key elements, barriers to operationalize the national MRV systems for crediting programs as well as provide recommendations to overcome the existing barriers. Therefore, the outcomes of this package will directly build up the country's competence in enhancing the capability toward the new, emerging reporting obligations under the PA.
Apart from following the action plan and recommendations that are proposed under the PMR, at a national level, Vietnam should articulate the rationale for availing flexibility that is not yet defined under the ETF for gradually improving the country's readiness to strike a balance between meeting the conditionality of targets and the information Vietnam is able to provide in tracking progress towards achieving its NDCs.
At the facility level, there are certainly more works need to be done to set up a robust MRV system since no implementing experience yet in the country, except for the implementation of CDM and JCM projects.

Plan as a Way to Strengthened Engagement
Vietnam has recently announced to strive for a low-carbon economy and tap into market opportunities for investment from domestic resources, international finance, and commercial sources. Since the promulgation of the National Green Growth Strategy-VGGS (2012) (Note 9), green growth and a low carbon economy have been ranked high on Vietnam's agenda and the notion of "low carbon development" has been the aim in the national green growth action plan as well the provincial action plans.
The VGGS-combining energy-, economic-, and climate policy-aims to "achieve a low carbon economy" (Note 26). The VGGS stated the objective "Green growth, as a means to achieve a low carbon economy and to enrich natural capital, will become the principal direction in sustainable economic development". The VGGS defines explicit emission reduction targets for the energy sector.
Vietnam now unconditionally commits itself to reduce its GHG intensity per unit of GDP by 8 to 10% by 2020 compared to 2010 levels and to reduce GHG emissions from energy activities by 10% (additional 10% conditional on international support) below business as usual by 2020 and 20% (additional 10% with international support) in 2030 (Note 9).
However, so far there is no system to MRV the low carbon economy targets and to connect to the NDC performance evaluation.
Though sounding cliché "we can't manage what we can't measure" but it is still very true and relevant in the case of low carbon development-how the low carbon targets can be in line and support for the targets under the NDC and vice versa without the system to measure the GHG emissions and reductions?
In VGGS, Vietnam also announced plans to move towards "trading of certified greenhouse gas emissions, carbon tax and fees and levies" (Note 9). This may pave the way for a stronger engagement by providing incentives for the sectoral ministries and private sectors with carbon pricing instruments such as a carbon tax, sectoral crediting, or an emissions trading scheme in the country's context, while the prerequisite for such pricing emissions is to build robust MRV scheme.
Hence, pursuing low carbon development path will raise the need for an MRV system to provide quantitative information to manage and evaluate the progress and outcomes. In its turn, a robust domestic MRV system will directly provide quantitative information to support decision making and operation in the transition process to a low carbon economy in the three levels, namely national, sectoral and facility in Vietnam. And enhancing of transparency policies under the ETF will certainly create the foundation on the monitoring the transition to a low carbon economy in Vietnam.
In diffusion of norms provided by the ETF, an enhanced MRV system at sectoral and facility level requires legal basis from the government and the governing agencies of various economic sectors, those in this case are the five main line ministries. Such legal documents shall follow the instruction of the national government where the implementation of low carbon economy is high in the political http://www.scholink.org/ojs/index.php/se Sustainability in Environment Vol. 5, No. 3, 2020 71 Published by SCHOLINK INC.
agenda. Several co-benefits that will attract the facility owners that the government can provide in the form of support for technology change and some types of tax exemption or financial support to the transition. Other aspects of co-benefits that local government, who directly manages the operation of the facility on regular basis, include employments generated from the change, improved environmental condition and health.
Those benefits can act as competitive advantage of the facility that decides to participate in the transition to the low carbon economy. Nevertheless, this transition cannot be realized without strong support from the government and its agencies at provincial and sectoral levels. It is best to legislate such support to gain the trust and willingness of the facility to broaden the scope or the transition.

Conclusions
Like many other developing countries, Vietnam is yet to streamline its domestic MRV system. The obligations to meet the ETF requirements in Vietnam can be built on the existing MRV framework and as such, some requirements under the ETF will already be met. But inevitably there will be several aspects of the ETF that Vietnam is not yet meeting. At the time of writing this paper there are still over four years before the first BTR must be submitted, meaning there is time to implement the necessary improvements.
As the international climate change framework developed through negotiation provided a flexibility in the ETF, by reflecting both needs for establishing universal system of transparency and the challenges held by developing countries. The bifurcated system provided a margin of congruence building for the Parties. At the national level in Vietnam, the MONRE played a role of norm-taker for the government, and with it high level of knowledge and expertise on the international transparency system, it has provided effective interpretation to facilitate diffusion of international norms to the domestic governance system.
Certainly, the flexibility provision should be determined to apply within the context of Vietnam to build adequate reporting capacities while complying the reporting set under the ETF. Responding to future challenge of complying with requirements under the ETF, would require an investment of resources and commitment by the country. This also implies the opportunity to promote and pursuing low carbon development path in the country via enhancing the domestic MRV mechanisms with wider participation of stakeholders. To this end, inclusive and extensive domestic stakeholder engagement is essential for conducting self-assessment and thereon building a robust framework. An integrated MRV system for GHG mitigation requires streamlined data management systems, technical capacity, improved analytical capabilities, and most importantly, active coordination amongst all the stakeholders.
So far, certain efforts have been made to build MRV for the specific sectors, actions, and programmes but not for GHG mitigation directly. MRV is currently scattered and varies with respect to policy, action, and sector. This results in a strong need to integrate all these individual actions into one Guidance on how best to use facility-level data that are not originally designed for national greenhouse gas inventory compilation. A new decision tree for selecting facility-level data is provided as well as good practice reporting considerations associated with facility-level data used in the national GHG inventory.