24 November 1997
ENGLISH ONLY
UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE
AD HOC GROUP ON THE BERLIN MANDATE
Eighth session, second part
Kyoto, 30 November 1997
Agenda item 3
1. At the first part of its eighth session, the Ad Hoc Group on
the Berlin Mandate (AGBM) considered the issue of greenhouse gas
sinks in the context of quantified emission limitation and reduction
objectives (QELROs) (FCCC/AGBM/1997/8).
2. At the same part of the session, Parties were invited to submit views on this topic by
12 November 1997. The secretariat was requested to compile these
submissions into a miscellaneous document.
3. The secretariat has received eight
submissions(1) which have already been
issued as document FCCC/AGBM/1997/MISC.4. The secretariat has
received five further submissions between 13 and 20 November 1997
from Australia, Canada, Iceland, Kenya and the United Kingdom of
Great Britain and Northern Ireland on behalf of the European
Community and its member States. In accordance with the procedure for
miscellaneous documents, these submissions are attached and are
reproduced in the language in which they were received and without
formal editing.
FCCC/AGBM/1997/MISC.4/Add.1
GE.97-
Submission No. Page
1. Australia 3
(Submission dated 14 November 1997)
2. Canada 10
(Submission dated 14 November 1997)
3. Iceland 16
(Submission dated 14 November 1997)
4. Kenya 19
(Submission dated 19 November 1997)
5. United Kingdom of Great Britain and
Northern Ireland 21
(On behalf of the European Community and
its member States)
(Submission dated 14 November 1997)
PROPOSED QUESTIONS FOR PARTIES REGARDING SINKS
(r2)
1. Should anthropogenic sinks be included or excluded in a QELRO?
Why or why not? (In responding you may wish to consider
which budget period or target year.)
The inclusion of anthropogenic sinks in national programs to
mitigate climate change is specifically provided for in the Climate
Change Convention and in the Berlin Mandate. Articles 4.1 and 4.2 of
the Convention relating to the commitments by Parties specifically
uses the phrase "anthropogenic emissions by sources and removals
by sinks of all greenhouse gases not controlled by the Montreal
Protocol" when dealing with inventories and mitigation action.
Drawing on the wording in these articles, the Berlin Mandate also
specifically states (article II 2 (a)) "This process will, inter
alia, (a) aim ...... for developed country Parties included in Annex
1 .... to set qualified limitation and reduction objectives .......
for their anthropogenic emissions by sources and removals by
sinks of greenhouse gases not controlled by the Montreal Protocol
...". Omitting sinks from QELROs would therefore be inconsistent with
both the Convention and the Berlin Mandate.
Australia believes anthropogenic sinks should be included in a
QELROs as part of a comprehensive approach, that is, one that covers
all greenhouse gases, all emissions, sources and sinks. The objective
of the Convention (Article 2) implies that greenhouse mitigation
action should cover areas that impact on the greenhouse gas
concentrations in the atmosphere. Enhancing removals of
greenhouse gases from the atmosphere is as important to this as is
reducing emissions by sources.
According to IPCC WG1 (Technical summary, Table 2) the land use
change and forestry sector accounts for around 25% of net
anthropogenic emissions, Therefore, LUCF cannot be omitted if
effective mitigation action is to be pursued.
Australia is therefore concerned that excluding sinks from a QELROs;
- removes any incentive to implement sink enhancement strategies even though they can make a major contribution to reducing net global and national emissions;
- prevents countries from receiving credit for any reductions in the level of net emissions achieved through sequestration activities;
- is to the advantages of countries whose national emissions
profile does not include a major contribution from
sinks.
Australia further believes adoption of the comprehensive approach for the first budget year is necessary because;
- it ensures that explicit consideration of the environmental impact of each greenhouse gas is taken into account by countries in responding to the climate change challenge;
- recognises different national emission profiles;
- enhances the cost effectiveness of national and global response;
- maximises the national response flexibility, as anything less
than a fully comprehensive approach would unfairly limit flexibility
and unfairly constrain the opportunities for cost effective action
for some parties.
2. What would be the impact of including or excluding
sinks on the QELRO levels, national plans or policies of your
country? (Please try to provide a qualitative
answer.)
Individual country's emission profiles differ and in this respect
Australia's profile is individual among Annex 1 countries, with the
energy sector accounting for only about half of our emissions
compared to an average of 80% for OECD countries. Land use change and
forestry account for around 20% of Australia's emissions, whereas
these sectors are a next sink for the majority of other Annex 1
countries. Sinks are therefore important in Australia to sustainable
land management.
In recognition of our situation, Australia's national greenhouse
response strategy, while addressing emissions from the energy sector,
also has a strong focus on LUCF sectors. This comprehensive approach
ensures our climate change mitigation action is appropriately
targeted to achieve maximum effectiveness.
Key programs that have a direct impact on human action include the
National Vegetation Initiative, a program which includes extensive
replanting of Australia's native vegetation cover, and the 2020
Vision, which aims to treble the plantation estate by
2020.
3. What criteria governed your answer to question number
1?
The criteria that governed Australia's response is its firm
support for the comprehensive approach, based on the fact that around
25% of world greenhouse emissions are from LUCF, that is, non-energy
sources. Such an approach maximises the cost effectiveness of
mitigation action through allowing individual countries to tailor
their approach to their own emissions profile. Australia sees the
principles surrounding the inclusion of sinks as a separate issue to
accounting mechanisms pertaining to sinks used in meeting
QELROs.
Australia is concerned that excluding sinks from a QELROs;
- removes any incentive to implement sink enhancement strategies even though they can make a major contribution to reducing net global and national emissions;
- prevents countries from receiving credit for any reductions in the level of net emissions achieved through sequestration activities;
- is to the advantages of countries whose national emissions
profile does not include a major contribution from
sinks.
As stated in Q1, Australia believes adoption of the comprehensive approach for the first budget year is necessary because it;
- ensures that explicit consideration of the environmental impact of each greenhouse gas is taken into account by countries in responding to the climate change challenge;
- recognises different national emission profiles;
- enhances the cost effectiveness of national and global response;
- maximises the national response flexibility, as anything less
than a fully comprehensive approach would unfairly limit flexibility
and unfairly constrain the opportunities for cost effective action
for some parties.
4. How would you define "anthropogenic" sinks in the
context of a QELRO?
Australia notes that the IPCC Guidelines for the National
Greenhouse Gas Inventory Reporting instructions refers to
'anthropogenic' as follows: "In general terms (it) refers to
greenhouse gas emissions and removals that are a direct result of
human activities or are the result of natural processes that have
been affected by human activities. Users may include any
human-induced emissions and removals in their inventory as long as
they can be clearly documented and quantified."
Australia has accepted the IPCC Guidelines, and has included LUCF
sectors in its national inventory. However, in deriving data for the
inventory, and in participation at workshops on LUC, Australia has
noted that the issue of the interpretation of the Guidelines has been
of concern to Parties. Australia would therefore suggest that work on
developing clearer Guidelines on how 'anthropogenic' is to be
interpreted be undertaken by SBSTA.
5. Do you agree or disagree with the following
proposition; if so why or why not? "Any QELRO that would include
sinks should be based on the 1996 IPCC Guidelines. Any new IPCC
methods would only apply to a second budget period or subsequent
target."
Australia agrees with the statement, and considers the current
IPCC Guidelines to be workable, while acknowledging that, of course,
they will continually be refined. Australia believes that the 1996
Guidelines should be applied for the full budget period, with any new
Guidelines being applied for the next period. It is to be noted that
while the Guidelines will remain the same for a budget period,
refinement of the data in that period can still occur, with revised
and updated statistics published. In this respect, Australia notes
that its inventory figure for 1990 has been revised three
times.
6. a) Which IPCC LUCF categories should be included or
excluded in a QELRO? Why? Examples: all land use change and
forestry/changes in forest and other woody biomass
stocks/other.
Australia believes that all terrestrial land areas should be
included to ensure a comprehensive coverage and assessment (of all
greenhouse gases, all emissions, sources and sinks), in accordance
with our response to Q1 and Q3.
b) If some categories are excluded, how should they be
dealt with?
Australia believes all categories agreed to be anthropogenic
should be included.
7. What reference year should be used as the basis for any
QELRO that would include sinks?
1990/2000/none/other.
The base year for measuring emissions needs to be the same for
both sources and sinks. Australia has used 1990 as its base year (and
has refined the data for that year) as it is used in Article 4.2 of
the Climate Change Convention and is featured in most QELROs
proposals.
Australia would oppose the option of not having a base year
(option 'none') as this would not provide any means of measuring and
including in QELROs improvements in sinks. It would, in fact,
undermine positive action to protect and enhance sinks.
8. a) How much uncertainty do you associate with the GHG
inventories provided by your country for the specific IPCC reporting
categories?
Australia notes the collection of greenhouse data as presented in
greenhouse gas inventory is a relatively new science, and that for
some categories of emissions (eg biological sources) estimations have
much refinement before they can match the precision of the energy
sectors. The IPCC Guidelines for national inventories recognise
varying levels of uncertainty, and seek to improve the quality of
inventory data and the surrounding uncertainty of the estimates
through checks for completeness and accuracy of inventories. The
guidelines ask that an uncertainty assessment be conducted and
summarised as far as possible for each major part of the inventory.
This is part of the transparent and open (unbiased) approach to a
country presenting its national inventory.
Uncertainty is inherent in estimations of GHG emissions and sinks
from all sectors. Given that varying levels of uncertainty will
exist, Australia believes that use of the same methodology over an
accounting period (uniformity of approach) should provide a
'consistent' measure acceptable for QELROs. In the biological
sectors, the levels of uncertainties may be higher than for other
sectors. Nevertheless, there are methodologies to enable estimates of
emissions to be made on a standardised basis. That is, greater
confidence can be held in the difference (trend line or net
emissions) between two periods (eg 1990 to 2000) where methodology
provides a standardised estimate, and errors in estimation are
systematic (e.g. an inaccurate emission factor applied to good
estimates of activity). In this context, Australia does not believe
it is necessary that the same methodology apply between countries;
indeed, it may not be appropriate to conditions in other countries,
only that it is applied consistently within one country and in one
period. Each country should be able to develop methodologies suitable
to itself in accordance with the IPCC guidelines.
The criteria used in Australia's inventory to define "high"
"medium" and "low" levels of confidence in the different sectors
reflects the quality of the activity data generally available in that
sector, and the confidence with which the relationships between
activity and emissions have been established. For example the quality
of activity data in energy use is high, and the relationships between
activity and emissions are comparatively simple, the confidence
criteria are more stringent than in other sectors.
|
Level of Confidence |
Energy, Transport, Fugitive emissions |
Agriculture, Forestry, Land use |
Industry Waste |
|
High |
Uncertainty<5% |
Uncertainty<20% |
Uncertainty<10% |
|
Medium |
Uncertainty 5-20% |
Uncertainty 20-80% |
Uncertainty 10-50% |
|
Low |
Uncertainty>20% |
Uncertainty>80% |
Uncertainty>50% |
Uncertainty in the emission estimates for each sector in Australia's National Greenhouse Gas Inventory can be summarised as follows:
. <5% for CO2 from fuel combustion and >20% for all other gases from fuel combustion
. <10% for CO2 and PFCs from industrial processes
. >20% for fugitive fuel emissions
. 20-80% for emissions from agriculture
. >80% for emissions from land use change and forestry
. >50% for emissions from waste.
Note that Australia expects the size of these uncertainties to
reduce as refinements in data occur over time.
b) What uncertainty levels would be appropriate for sinks
in a QELRO, bearing in mind the uncertainties associated with
sources?
Australia believes that while there are uncertainties associated
with the definition and measurement of sinks, there are adequate
methods available if rigorously applied to enable sinks to be
included in a QELRO.
c) How should uncertainty be dealt
with?
See response to Q8 a) above. The IPCC Guidelines for national
inventories recognise varying levels of uncertainty, and seek to
improve the quality of inventory data and the surrounding uncertainty
of the estimates through checks for completeness and accuracy of
inventories. It asks that an uncertainty assessment be conducted and
summarised as far as possible for each major part of the inventory.
This is part of the transparent and open (unbiased) approach to a
country presenting its national inventory.
Australia believes that these accepted IPCC Guidelines provide a
reasonable standardised approach for dealing with uncertainties.
Restricting QELRO to those sectors that have inventory data with high
confidence levels assumes that no further improvement to estimation
techniques are possible.
9. Should there be a limit on the amount of sinks in a
QELRO; if so how should it be determined?
Australia believes that all national sinks relevant to a country's
emissions profile should be included. With a comprehensive approach
to QELROs, countries will select sink activity most appropriate to
their emission profile and to achieving QELROs. Inclusion of sinks in
a QELRO naturally implies inclusion in both the reference year and in
the budget period.
10. Is the data provided in national communications
adequate/inadequate for assessing compliance with a QELRO? Why or why
not?
See response to Q8 a). The current guidelines for national
communication requires data on all sectors and on both sources and
sinks. Australia believes that the accepted IPCC Guidelines provide a
reasonable standardised approach for dealing with uncertainties in
inventory data as presented in national communications. This is part
of the transparent and open (unbiased) approach to a country
presenting its national inventory.
Countries will be required to justify their results as reported in
their national communication to the Review Team from the FCCC, and
while countries should report on all sink activity, only those sinks
reported on in the national communication should be claimed against a
QELROs. Australia therefore views this review mechanism as very
important, and believes this should prove adequate for assessing
compliance with QELROs. Australia's forthcoming national
communication and its inventory for 1995 have substantially reduced
uncertainties from the first national communication, due to the
ongoing work in the LUCF sectors.
11. Should any "national system" established under Article
4 [Article 5 in the latest draft] give special consideration to
sinks?
Australia views sinks as an integral part of Article 5. Article 5
of the Chairman's text states "Each Party included in Annex 1 ....
shall have in place ..... a national system for the estimation of
anthropogenic emissions by sources and removals by sinks of all
greenhouse gases not controlled by the Montreal Protocol". This text
reflects that also found in the Climate Change Convention and the
Berlin Mandate. The handling of sources and sinks should reflect the
relative weight between these two in a country's greenhouse
profile.
12. In order to achieve compliance with a QELRO
(with/without sinks), what activities should be credited or not
credited and what base year should be used?
Australia believes in a comprehensive approach, covering all
greenhouse gases, all emissions, sources and sinks (see Q1 and Q3),
and, therefore, all activities relating to sink enhancement, in line
with IPCC Guidelines, should be credited, provided they are reported,
with measurement, in a country's national communication and are
subject to the review mechanism (see Q10). Refer to Q7 re base
year.
13. What definitions should be included; in which article
of the protocol?
Australia notes that the IPCC Guidelines provides a working
reference to the term 'anthropogenic' (refer to Q4). The wording in
the Convention (Article 4.1) "emission by sources and removals by
sinks" gives a working interpretation of "net
emissions".
14. Do you have any other approach to
propose?
No comment.
15. Do you have specific protocol
language?
No comment.
1. Should anthropogenic sinks be included or excluded in a QELRO?
Why or why not? (In responding you may wish to consider which budget
period or target year.) Yes, further explanation is given
in paragraphs 1, 2,3 and 4
2. What would be the impact of including or excluding sinks on the
QELRO levels, national plans or policies of your country? (Please try
to provide a qualitative answer.) Please see paragraphs 4
& 5.
3. What criteria governed your answer to question number 1?
Criteria are outlined in paragraphs 1,2,3,4 and
5.
4. How would you define "anthropogenic" sinks in the context of a
QELRO? Please refer to paragraph 3 and note that sinks
should be considered in the context of land-use change & forestry
and not in isolation of sources.
5. Do you agree or disagree with the following proposition; if so
why or why not? "Any QELRO that would include sinks should be based
on the 1996 IPCC guidelines. Any new IPCC methods would only apply to
a second budget period or subsequent target." Not
entirely, please see paragraphs 7,10,and
11.
6. a) Which IPCC LUCF categories should be included or excluded in a QELRO? Why? Examples: all land use change and forestry/Changes in forest and other woody biomass stocks/other.
b) If some categories are excluded, how should they be dealt
with? None, please see paragraph
3.
7. What reference year should be used as the basis for any QELRO
that would include sinks? 1990/2000/none/other Please see
paragraphs 4, 5 and 6 - answer is 1990.
8. a) How much uncertainty do you associate with the GHG inventories provided by your country for the specific IPCC reporting categories?
b) What uncertainty levels would be appropriate for sinks in a QELRO, bearing in mind the uncertainties associated with sources?
c) How should uncertainty be dealt with? Please see paragraphs
8 - 14 inclusive.
9. Should there be a limit on the amount of sinks in a QELRO; if
so how should it be determined? No, for explanation see
paragraph 6.
10. Is the data provided in national communications
adequate/inadequate for assessing compliance with a QELRO? Why or why
not? Historical national communications should not be used as the
basis for measuring compliance. This issue has not been adequately
dealt with. Please see paragraphs 10 and 11, as well as
8,9,12,13 and 14.
11. Should any "national system" established under Article 4 give
special consideration to sinks?
12. In order to achieve compliance with a QELRO (with/without
sinks), what activities should be credited or not credited and what
base year should be used? Please see paragraphs 3 and
4.
13. What definitions should be included; in which article of the
protocol? Definition as per paragraph
3.
14. Do you have any other approach to propose? Please
see paragraphs 3,7 and 9.
15. Do you have specific protocol language? Please see
paragraphs 11 and 12.
1/
The Framework Convention on Climate Change is unclear on how to
treat emissions and carbon sequestration from land use change and
forestry both in terms of a country's national inventory and any
legally binding commitment. It states that "Each Party
shall... limit its anthropogenic emissions of greenhouse gases and
protect and enhance its greenhouse gas sinks and
reservoirs". While there are different interpretations
of this statement's meaning, it is clear that sinks are to be
included under the Convention.
2/
The Framework Convention also defines a sink as "any
process, activity or mechanism which removes a greenhouse gas, an
aerosol, or a precursor of a greenhouse gas from the
atmosphere". Currently undefined is the term
anthropogenic. While the term human induced
has been used as a substitute for anthropogenic and has found
widespread acceptance for emissions from industrial processes and
fossil fuel combustion, it is not so easily applied to forestry and
sinks, which are essentially natural processes. Because of the
cyclical nature of forest systems, and because of the dominating
influence of natural forests in certain countries, such as Canada,
any legally binding instrument should treat forests in a unique
manner.
3/
Any approach that fosters the enhancement of sinks, and reduces
the incentives to de-forest should be endorsed. As such, a more
precise definition for anthropogenic sinks is needed and the
following is proposed: " Direct human activities
undertaken after [1990](2) aimed at
enhancing sink capacity,(specifically reforestation and
afforestation) and that affect carbon stocks and that can be
verified". For clarity, all further references in this
response to sources and sinks refer to anthropogenic sources and
sinks, and are made in the context of the definition of anthropogenic
sinks as stated above.
4/
Anthropogenic
Anthropogenic sinks, as defined above, should be included in a
QELRO. It is vital that a protocol to the Convention provide
incentives that encourage activities aimed at protecting carbon
stocks and enhancing sinks. The exclusion of sinks from a QELRO
removes much of the incentive to undertake these types of activities.
Furthermore, by narrowing the definition of anthropogenic to direct
activities that change carbon stocks after the target year, many of
the uncertainties associated with the land-use change and forestry
methodologies are reduced. Any approach that is restricted
to new activities is not only easier to
verify because of an increase in precision afforded by real and
measurable data, but is also more equitable by providing a level
starting point.
5/
Suggestions have been made that to do otherwise would grandfather
the 1990 rates of deforestation and would, therefore, be in conflict
with Article 4.2(a) which commits parties to protect and enhance
sinks and reservoirs. Parties either commit to an annual rate of
carbon removal or emissions from land use practices. These
commitments are unsustainable. In countries that are currently
sequestering carbon, as forests reach maturity, net removals become
zero. On the other hand, countries with net losses from sinks
eventually reach limits to further deforest, and as a result their
emissions reach zero. The result of this is to reward deforesters,
ie. their target is based on a current rate of deforestation so they
are free to continue deforesting, while it penalizes afforesters,
countries that are currently sequestering carbon, but may not be able
to maintain their current sequestration rates.
6/
QELRO & Net Approach
A legally binding target would be defined with reference to 1990
gross anthropogenic emissions from fossil fuels and industrial
processes for all gases and all sources, excluding carbon dioxide
emissions from biomass. Compliance would be measured as the net of
gross anthropogenic emissions and subsequent anthropogenic emissions
and removals from land-use change and forestry (LUCF) activities
after 1990. To postpone the date from which actions would be measured
would only serve to postpone action. At this time Canada believes
that no limit should be placed on anthropogenic sinks in a QELRO
since the goal of the Convention is to reduce atmospheric
concentrations and how that is achieved should not be
predetermined.
7/
The current 1996 IPCC Guidelines should be used as the basis upon which to develop emission and removal estimates and uncertainties should be examined in the context of all anthropogenic sources and sinks, not just within the LUCF sector. Any new methodologies, particularly those that deal with the issue of uncertainties, that are developed and agreed to at a Meeting of the Parties, and available within an appropriate time frame prior to the first budget period, would apply to the first and subsequent budget periods, notwithstanding any future agreements by the Parties. Parties are expected to improve their data for all sources and sectors as they develop their emission inventories and the requirement to undertake more extensive data collection systems is not an acceptable argument for not including a particular source or removal.
8/
Uncertainties
The issue of uncertainty(3) should
be examined in the broader context of all gases and all anthropogenic
sources and sinks. Suggestions have been made that the issue of
uncertain emission estimates can more easily be addressed by
narrowing the focus of the binding quantified emission limitation and
reduction objectives (QELROs) to the few sources most easily
estimated. For reasons of flexibility, lack of a clear point at which
to make a distinction between certainty and uncertainty, and the
inherent uncertainties even within the most certain categories, this
position is not endorsed by Canada.
9/
If we were to eliminate some sources from an inventory, or a
QELRO, solely because of the uncertainty in the emission estimates,
we might also be eliminating an area in which large and measurable
gains could be made in reducing emissions, or in enhancing the
removal of carbon dioxide from the atmosphere. By excluding forestry
and hence afforestation, reforestation and deforestation from a
QELRO, we fail to foster the sustainability of existing forests and
are therefore in conflict with the aims of the
Convention.
10/
Determinations of compliance will be based on each Party's
emissions inventory, which should be prepared using methods designed
specifically for this purpose; i.e., 1996 Revised IPCC Guidelines.
Nevertheless, given the variety of methods currently available for
preparing inventories for each anthropogenic source and sink, and the
different uncertainties associated with each method, the issue of
uncertainties needs to be addressed prior to the start of the first
budget period.
11/
Verification
Canada, along with many other Parties, strongly believe that
future changes in the Guidelines are necessary. In this regard,
Canada would like to propose that improved methods for inventorying
all anthropogenic sources and sinks of greenhouse gases be developed
based on the work of the IPCC and other expert groups and that the
Parties adopt revised guidelines on the use of these methods at a
Meeting of the Parties to the Kyoto agreement prior to the first
budget period.
12/
Canada would also like to propose that Parties provide a
quantitative estimate of the uncertainties associated with their
greenhouse gas inventories using appropriate methodologies to be
developed based on the work of the IPCC and other expert Groups and
that the Parties adopt these methodologies at a Meeting of the
Parties to the Kyoto agreement prior to the first budget
period.
13/
These revised methodologies and guidelines would establish an
approach in which all Parties could be assured that those
anthropogenic sources and sinks for which a measure of certainty is
less precise are, in fact, in
compliance(4). Ideally, it is hoped
that a table of scaling factors by source, gas and methodology would
be developed by the IPCC, or other expert group along with
appropriate uncertainty values for each of the methods.
14/
These scaling factors would then be applied against country
emission estimates in much the same way GWPs are used now. In effect,
the weighting or scaling of emissions would not only recognize and
deal with the significant differences in the accuracy of estimates
and the measurement/verification of emissions and reductions, it
would also provide an equitable way in which to offset emission
increases from well defined sources with reductions made in less well
defined areas, as well as ensure that a country is meeting its stated
commitment. An additional benefit is that the weighting system could
also be used for point or project level sources and in a trading
system.
Questions from the chair of informal contact group on
sinks.
Response from the Icelandic delegation.
1. Should anthropogenic sinks be included or excluded in a QELRO?
Why or why not?
Yes, anthropogenic sinks should be included in a QELRO. It is vital that a
protocol to the Convention provides strong incentive for
activities aimed at protecting carbon stocks and the enhancement of
sinks. This can only be done through including sinks in
QELROs.
2. What would be the impact of including or excluding sinks on the
QELRO levels, national plans or policies of your
country?
Anthropogenic enhancement of removals by sinks of atmospheric
carbon dioxide is an important component of the current Icelandic
National Climate Change Action Programme. If sinks are not included
in a protocol this would limit Iceland's ability to set ambitious
QELROs.
3. What criteria governed your answer to question number
1?
The fundamental criteria is the fact that the biosphere has
significant impact on the atmospheric concentration of carbon
dioxide. It has been estimated that terrestrial sinks have removed
carbon dioxide equal to 38% of annual emissions from fossil fuel
combustion. There are strong indications that this enhancement of
uptake by terrestrial ecosystems and the resulting delay in carbon
dioxide build-up in the atmosphere will prove to be short lived. It
is vital that a protocol to the Convention provides strong incentive
for enhancement of carbon dioxide removal by sinks in the
future.
According to 1/CP.1, the Berlin Mandate shall be guided, inter
alia, by the coverage of all greenhouse gases, their emissions by
sources and removals by sinks and all relevant sectors. It is
therefore in full accordance with the Berlin Mandate to include sinks
in QELROs.
Additional criteria is the fact that sinks provide added
flexibility to Parties to select actions with the lowest cost and
highest environmental benefit.
4. How would you define "anthropogenic" sinks in the context of a
QELRO?
The sinks themselves are generally natural (growing forest,
accumulation of organic matter (carbon) in soils). Man can enhance
the carbon dioxide uptake of these sinks through direct actions,
however. Such enhancement of removals by sinks is anthropogenic. In
the context of QELROs, anthropogenic enhancement of sinks should be
defined rather narrowly to include only direct actions such as the
planting of forests, application of fertilizers to forests, exclusion
of grazing or revegetation activities.
The IPCC should be asked to provide criteria for the determination
of which actions can be considered anthropogenic enhancement of
sinks. Applying such criteria Parties should, on a case by case
basis, justify why their actions qualify as removal through
anthropogenic enhancement of sinks. The burden of proof rests with
the Party.
5. Do you agree or disagree with the following proposition; if so
why or why not? "Any QELRO that would include sinks should be based
on the 1996 IPCC guidelines. Any new IPCC methods would only apply to
a second budget period or subsequent target."
The 1996 IPCC guidelines should be used for the quantification of
the carbon dioxide removal resulting from individual projects or
actions. It should be remembered, however, that the IPCC guidelines
encourage the use of more detailed national methods when available.
This approach is sound and should be maintained.
It takes time for revised IPCC guidelines to be implemented and
their use is not mandatory for a few years after their adoption. The
best available methods should always be used. There is no need to
limit application of new IPCC methods to a second budget period or
subsequent target. Such a limitation could further delay the
incorporation of improved science into the quantification of sinks
and could delay the process of reducing uncertainty in this
area.
6. a) Which IPCC LUCF categories should be included or excluded in a QELRO? Why? Examples: all land use change and forestry/Changes in forest and other woody biomass stocks/other.
b) If some categories are excluded, how should they be dealt
with?
a) There is no need to limit the LUCF categories to be included.
This only limits the flexibility of Parties to select the most
practical means to achive their QELRO. Applying the criteria to be
provided by the IPCC (see response to question 4 above), Parties
should through their national reporting include all relevant
categories.
b) The exclusion of certain categories could provide perverse
incentive resulting in the continuation of land use practices leading
to significant increase in emissions from LUCF categories not covered
by a protocol. If LUCF categories are excluded, credits for
categories included in a protocol should be conditional on
appropriate management of LUCF categories not covered by a
protocol.
7. What reference year should be used as the basis for any QELRO that would
include sinks? 1990/2000/none/other.
1990, the same year as for QELRO.
8. a) How much uncertainty do you associate with the GHG
inventories provided by your country for the specific IPCC reporting
categories? b) What uncertainty levels would be appropriate for sinks
in a QELRO, bearing in mind the uncertainties associated with
sources? c) How should uncertainty be dealt with?
Iceland has so far only reported GHG inventories for direct actions taken to sequester carbon through aforestation and revegetation. The uncertainly
associated with this approach is significantly lower that the
uncertainty associated with establishing carbon budgets for all land
cover types.
9. Should there be a limit on the amount of sinks in a QELRO; if
so how should it be determined?
There is no need for a limit on the amount of sinks in a QELRO. At
the same time all Parties must recognise that the enhancement of
sinks can only be supplementary to other policies and measures for
addressing the climate change issue. If limits are imposed, however,
care should be taken to ensure that they do not remove the incentive
for action to enhance sinks.
10. Is the data provided in national communications adequate/inadequate for
assessing compliance with a QELRO. Why of why not?
If the national communications are based on the 1996 IPCC
guidelines for the quantification of sink uptake, they would be
adequate for assessing compliance with a QELRO. The review process
has to be comprehensive, however, to ensure consistency and
comparability.
11. Should any "national system" established under Article 4 give
special consideration of sinks?
Yes, it is vital to have good national accounting systems for
anthropogenic enhancement of sinks.
12. In order to achieve compliance with a QELRO (with/without
sinks), what activities should be credited or not credited and what
base year should be used?
See response to questions 4, 6 and 7.
13. What definitions should be included; in which article of the
protocol?
In Article 1: "Anthropogenic enhancement of sinks" is the result
of direct actions taken by Parties to enhance the removal of carbon
dioxide from the atmosphere by natural or anthropogenic
sinks.
14. Do you have any other approach to propose?
As reflected in the response to the questions above we suggest
that the inclusion of sinks in a protocol be limited to the
anthropogenic enhancement of carbon uptake which results from direct
action taken after 1990. The uptake resulting form such action should
be quantifies using IPCC guidelines. Before crediting the result of
such actions to the Party's QELROs, the Party should provide an
analysis of the impact changes in land use have on emissions from
LUCF. Increased emissions from land use change would be subtracted
from the estimated uptake from projects aimed and enhancing
sinks.
15. Do you have specific protocol language?
No
1. Should anthropogenic sinks be included or excluded in aQELRO?
Why or why not (In responding you may wish to consider which budget period
or target year).
A: Any other than forest and land use
change
2. What would be the impact of including or excluding sinks on the
QELRO levels, national plans or policies of your country? (Please try
to provide a qualitative answer).
A: Including sinks would interfere with management and
utilisation of land resources including
forest
3. What criteria governed your answer to question number
1?
A: Land resources and forest are crucial to national
economic development in Kenya.
4. How would you define "anthropogenic" sinks in the context of
QELRO?
A: Any system/process created/developed for the sole
purpose of absorbing greenhouse gases.
5. Do you agree or disagree with the following proposition; if so why or why not?
"Any QELRO that would include sinks should be based on the 1996 IPCC Guidelines.
Any new IPCC methods would only apply to a second budget period or
subsequent target."
A: Disagree because the question of sinks is highly
complex and should not subject to time frame of
assessment.
6. (a) Which IPCC LUCF categories should be included or excluded in a QELRO?
Why? Examples: all land use change and forestry/changes in forest
and other wooody biomass stocks/other
(b) if some categories are excluded, how should they be dealt
with:
A: (a) None
(b) None
7. What reference year should be used as the basis for any QELRO
that would include sinks? 1990/2000/none/other.
A: Question difficult to
answer
8. (a) How much uncertainty do you associate with GHG inventories provided by your country for the specific IPCC reporting categories?
(b) QELRO, bearing in mind the uncertainties associated with
sources?
(c) How should uncertainty be dealt with?
A: (a) 100%
(b) equal to that of
sources
(c) difficult to answer
9. Should there be a limit on the amount of sinks in a QELRO; if
so how should it be determined?
A: No and if there should be, it should be equal to or
greater than emission in a country.
10. Is the data provided in national communications
adequate/inadequate for assessing compliance with a QELRO? Why or why
not?
A: No because of most of the information is too
subjective.
11. Should any "national system" established under Article 4 give
special consideration to sinks
A: Yes
12. In order to achieve compliance with a QELRO (with/without
sinks), what activities should be credited or not credited and what
base year should be used?
A: Emissions reduction 1990
13. What definitions should be included; in which article of the
protocol?
A: Difficult
14. Do you have any other approach to propose?
A: Amount of sinks in each country should be equal or
greater than the total amount of emissions of that country per
year.
1. Should anthropogenic sinks be included or excluded in a QELRO? Why or why not? (In
responding you may wish to consider a budget period or year)
Parties included in Annex I shall, individually or jointly, ensure
that their aggregate anthropogenic carbon dioxide equivalent
emissions by sources of the greenhouse gases listed in Annex A do not
exceed their commitments, expressed in terms of emissions budgets,
inscribed in Attachment 1.
Subject to relevant modalities, rules and guidelines, to be
decided by the first MOP, Parties that apply the methodologies
referred to under Article 4 may count their enhancement of removals
by sinks against their aggregate anthropogenic CO2
equivalent emissions by sources under Article 3.1.
2. What would be the impact of including or excluding sinks on
the QELRO levels, national plans or policies of your country? (Please
try to provide a qualitative answer).
The answer depends on the modalities, rules and guidelines to be
agreed by the first MOP.
3. What criteria governed your answer to question number
1?
The answer is governed by the agreed position of the EU, which
recognises the desirability of eventually taking into account sinks
in QELROs, once the modalities for doing so can be
agreed.
4. How would you define 'anthropogenic' sinks in the context
of a QELRO?
Anthropogenic sinks are processes which remove greenhouse gases
from the atmosphere and are influenced (positively or negatively) by
human activity. In practical terms anthropogenic sinks are sinks
included in the IPCC Guidelines for National Greenhouse Gas
Inventories. The inclusivity of source and these sink categories is
kept under review by IPCC as part of its inventory programme.
Technical issues to be addressed include the status of additional
carbon sequestration due to C and N fertilization from anthropogenic
emissions.
5. Do you agree or disagree with the following proposition; if
so why or why not? 'Any QELRO that would include sinks should be
based on the 1996 IPCC Inventory Guidelines. Any new IPCC methods
would only apply to a second budget period or subsequent
target.'
The modalities, rules and guidelines for assessing QELROS which
include sinks should be based on the IPCC 1996 Guidelines, and any
relevant material which emerges subsequently and leads to revision of
the IPCC Guidelines. The relevant modalities, rules and guidelines
will be decided by MOP1. The EU does not consider that these should
be changed during a budget period.
6a) Which IPCC LUCF categories should be included or excluded
in a QELRO? Why? Examples: all land use change and forestry/changes
in forest and other woody biomass stocks/other.
All quantifiable anthropogenic sinks should be included, subject
to the decisions of MOP1. If in practice MOP1 decided to omit some
sinks from early budget periods (eg because of data availability or
incompleteness of the IPCC methodology), inclusivity would still need
to be sufficient to avoid the perverse incentive of planting trees on
soil types which then become sources.
6b) If some categories are excluded, how should they be dealt
with?
Parties should report separately inventory data for any sink
categories excluded from the QELRO. The general commitment under the
Convention, to protect and enhance sinks, would still apply, and
legally binding Policies and Measures should be applicable to any
categories that were excluded.
7) What reference year should be used as the basis for any QELRO that would include sinks?
1990/2000/none/other?
The EU has always proposed 1990 as the base year for any
QELRO.
8a) How much uncertainty do you associate with the GHG
inventories provided by your country for the specific IPCC reporting
categories?
The systematic uncertainty in energy related to CO2 may
be about 5%. For methane the overall uncertainty is estimated to be
about 20% to 30%. Nitrous oxide from industrial processes is known as
accurately as energy related CO2, although nitrous oxide
from soils may be uncertain to an order of magnitude. For some
fluorocarbons there is an additional element of uncertainty depending
on how delayed releases are taken into account. These systematic
uncertainties do not necessarily imply similar levels of
uncertainties in measuring changes over time, as with standardised
and comparable methodologies such errors tend to cancel out. The
overall uncertainty in the percentage difference in GWP weighted
emissions between two years may be of the order 1%.
8b) What uncertainty levels would be appropriate for sinks in
a QELRO, bearing in mind the uncertainties associated with
sources?
This would, in the EU's view, be an issue for MOP1 to consider.
Present technical evidence is that the uncertainty in the forest sink
is around 10 to 15%, and soil sink around 50%. These levels of
uncertainty are within the range of uncertainties for emissions
categories in national inventories, although under the gross/net
approach the sink uncertainties would have greater implications for
compliance than would be the case for uncertainty in an emissions
category. The larger uncertainty is because the adjustment would
depend on the absolute uptake by sinks over the budget period, not
emissions in the budget period relative to the base year. Therefore
the usual cancellation of systematic errors does not occur, and under
a gross/net approach any allowances would have the same uncertainty
as the sink category itself (ie 15% or 50% (or more) for the forest
and soil sink respectively). This is a larger uncertainty than
usually occurs on an emissions trend.
8c) How should uncertainty be dealt with?
By the MOP agreeing the modalities to be used for sinks estimation
and the allowable level of uncertainties.
9) Should there be a limit on the amount of sinks in a QELRO;
if so, how should it be determined?
The EU considers that any application of limits would be a matter
for the first MOP to consider. If limits were applied, there could be
a cap or discount on the adjustment, to maintain incentives for
action on gross emissions mitigation (since sinks cannot be increased
indefinitely), or allow for the effect of uncertainties on compliance
as discussed under 8b.
10) Is the data provided in national communications
adequate/inadequate for assesing compliance with a QELRO? Why or why
not?
Adequacy on the nature of the QUELRO agreed. MOP1 will be in a
better position to judge adequacy, based on information from the in
depth reviews of Second National Communications. So far we can judge
at present, Second National Communications appear in most (but not
all) cases to have data on uptake by forests. Soils data are much
more sparse.
11) Should any 'national system' established under Article 4
give special consideration to sinks?
All national systems meeting the requirements of Article 4 should
give consideration to sinks adequate for the purpose of inventory
reporting. This would require the development of institutional
mechanisms for data gathering on sinks if these are missing at
present.
12) In order to achieve compliance with a QELRO (with/without
sinks), what activities should be credited or not credited, and what
base year should be used?
The definition of the QELRO should be in terms of all aggregate
anthropogenic emissions by sources identified in the IPCC Methodology
as referred to under Article 4. Subject to relevant modalities, rules
and guidelines, to be decided by the first MOP, Parties that apply
the methodologies referred to under Article 4 may count their
enhancement of removals by sinks against their aggregate
anthropogenic CO2 equivalent emissions by sources. In
particular, the MOP will need to decide the extent to which
activities and/or sink categories should be credited, and from which
year. Sink reversal (negative adjustment) will also be relevant,
because sink categories can change from sinks to
sources.
13) What definitions should be included, in which article of
the Protocol?
The definitions requires would depend on the nature of the agreed
QELRO
14) Do you have any other approach to
propose?
See response to 15 below
15) Do you have specific protocol language?
Yes. See response to question 1 above