A/HRC/33/40 framework, except when there is a consensus on them at a ministerial conference.50 Yet, at the Bali Ministerial Conference, held in 2013, the developing countries surrendered their most powerful leverage when they conceded the Trade Facilitation Agreement as a separate accord. Bearing in mind that that Agreement has not entered into force, one may suggest the developing countries withhold deposit of their instruments of ratification until they secure their own demands, including Nairobi decisions on “deliverables”, in a single protocol incorporating the results of the Doha Work Programme. 69. The outcome document of the eleventh session of the Parliamentary Conference on WTO, held on 13 and 14 June 2016, states: “We appreciate the decision on public stockholding for food security purposes and call for the conclusion of negotiations on finding a permanent solution to the issue … We believe that the issue of food security is vital for developing countries and that WTO rules must support efforts to combat hunger. In line with the same decision, we also want to stress the importance of a speedy adoption of a proposal for a special safeguard mechanism … Flexibility, openness, inclusiveness and political engagement will be key to advancing on all the remaining issues of the Doha Development Agenda.” VII. World Trade Organization dispute settlement 70. On 24 February 2016, a WTO dispute panel adopted a decision against the efforts of India to create renewable energy through the extended use of solar panels.51 One would think that, after the Conference of the Parties to the United Nations Framework Convention on Climate Change, everyone would support such initiatives, but WTO dispute panels seem to be caught in their own mantras and incapable of showing flexibility in accommodating the new priorities imposed by climate change. Despite some interesting initiatives in that field, such as the WTO Committee on Trade and Environment, there is still unwillingness to interpret broadly the general exceptions provided under the General Agreement on Tariffs and Trade 1994.52 71. The National Solar Mission of India, which aims at increasing the country’s renewable energy in line with Sustainable Development Goal 7 on ensuring access to affordable, reliable, sustainable and modern energy for all, is a reasonable plan. It would create local jobs and bring clean energy to millions by generating 100 gigawatts of solar power annually, consistent with the goals of the Framework Convention on Climate Change. The WTO case was brought by the United States, which challenged the domestic content clause of India, which would require part of the solar cells to be produced nationally. India unsuccessfully tried to reach a settlement with the United States and now may have to adjust its solar programme to avoid WTO sanctions. The panel concluded that the measures of India were inconsistent with article 2.1 of the Agreement on Trade-Related Investment Measures and article III:4 of the General Agreement on Tariffs and Trade 1994, and were not covered by the derogation in article III:8 (a) of that General Agreement, or justified under the general exceptions in articles XX (j) and XX (d) of that General Agreement. The panel concluded that benefits accruing to the United States had been 50 51 52 16 http://thewire.in/17950/news-of-dohas-death-may-be-premature-but-india-china-must-fight-to-savethe-day/; Chakravarthi Raghavan, The Third World in the Third Millennium CE (Penang, Third World Network, 2014). www.wto.org/english/news_e/news13_e/ds456rfc_06feb13_e.htm; www.ictsd.org/bridges-news/biores/news/us-launches-new-wto-challenge-against-india-solarincentives; and www.wto.org/english/tratop_e/dispu_e/cases_e/ds456_e.htm. www.wto.org/english/docs_e/legal_e/06-gatt_e.htm. GE.16-11938