27 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 thirteen
submissions(1) which have already been
issued as documents FCCC/AGBM/1997/MISC.4 and Add.1. The secretariat
has received two further submissions between 20 and 27 November 1997
from the Russian Federation and Uzbekistan. In addition, the
secretariat has received three revised submissions from Australia,
Canada and Peru, and one comment on the responses received from
Parties to the sinks questionnaire (New Zealand). 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.2
UKY.97-71076
Submission No. Page
1. Australia 3
(Revision)
(Submission dated 24 November 1997)
2. Canada 10
(Revision)
(Submission dated 21 November 1997)
3. New Zealand 11
(Comment on the responses received from Parties
to the sinks questionnaire)
(Submission dated 25 November 1997)
4. Peru 14
(Revision)
(Submission dated 25 November 1997)
5. Russian Federation 15
(Submission dated 24 November 1997)
6. Uzbekistan 16
(Submission dated 18 November 1997)
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 use 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 quantified 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's view is that anthropogenic sinks should be included in
a QELRO as part of a comprehensive approach that covers all
greenhouse gases and all emissions sources and sinks. The objective
of the Convention (Article 2) is 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 as is reducing emissions from
sources.
According to IPCC WG1 (Technical summary, Table 2) the land use
change and forestry sector accounts for around 25% of net
anthropogenic emissions. The net emissions from this sector are the
product of emissions from sources and removals by sinks. Sinks are
clearly an important part of the response action to achieve the
objectives of the Climate Change Convention.
Australia is therefore concerned that excluding sinks from QELRO;
- removes incentives 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 reductions in the level of net emissions achieved through sequestration activities;
- disadvantages countries whose national emissions profile
includes a major contribution from sinks.
Australia supports adoption of the comprehensive approach for the first budget period because it;
- ensures that countries explicitly consider the environmental impact of all greenhouse gases in all sectors in responding to the climate change challenge;
- recognises different national emission profiles and consequent varying national circumstances;
- recognises the significance of both sources and sinks to global contributions to greenhouse gas emissions;
- 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.)
Countries have different emission profiles. In this respect
Australia's profile is significantly different when compared to other
Annex 1 countries. The energy sector accounts for only about half of
Australia's net emissions (compared to an average 80% for OECD
countries) while the land use change and forestry sector accounts for
around 20% of Australia's net national emissions in
1990.
Although in Australia land use change and forestry represents a
net source of emissions, sinks are also an important component
comprising around 20% of net national emissions. In contrast, for
other Annex 1 countries, the land use change and forestry sector is
generally of low significance in the overall emissions pattern and,
in almost all cases, represents a net sink.
In recognition of our situation, Australia's national greenhouse
strategy, while addressing emissions from the energy sector, also has
a strong focus on the land use change and forestry sector,
particularly including protection and enhancement of sinks. This
comprehensive approach ensures Australia's climate change mitigation
action is targeted to achieve maximum effectiveness and incorporate
significant components of the national profile.
Australia's key sink protection and enhancement programs include:-
- the National Vegetation Initiative which includes extensive replanting of Australia's native vegetation cover, and Bushcare (A$350M); and
- 2020 Vision which aims to treble Australia's 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 land use change and
forestry, 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 therefore concerned that excluding sinks from QELROs;
- removes incentives 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 reductions in the level of net emissions achieved through sequestration activities;
- disadvantages countries whose national emissions profile
includes a major contribution from sinks.
As stated in Q1, Australia supports adoption of the comprehensive approach for the first budget year because it;
- ensures that countries explicitly consider the environmental impact of all greenhouse gases in all sectors in responding to the climate change challenge;
- recognises different national emission profiles and consequent varying national circumstances;
- recognises the significance of both sources and sinks to global contributions to greenhouse gas emissions;
- 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?
The IPCC Guidelines for the National Greenhouse Gas Inventory
Reporting instructions refer 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.'
The IPCC Guidelines have been adopted by the Conference of the
Parties as an integral part of guidelines for preparation of national
communications and national inventories. In interpreting development
of the National Greenhouse Gas Inventory, Australia has followed
these guidelines and included all activities resulting in both
sources and sinks.
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 supports the view that the 1996 Guidelines should be
applied for the full budget period, with any new Guidelines being
applied for the next period.
The IPCC guidelines allow refinements to activity data and methods
used in compiling national inventories. Any changes to compiling
inventory emissions estimates should be applied consistently by a
country to the base year and the budget period when assessing
compliance with a QELRO.
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 supports inclusion of all terrestrial activities to
ensure a comprehensive coverage and assessment (of all greenhouse
gases and 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 supports inclusion of all categories agreed to be
anthropogenic.
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 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'). A transparent, credible and environmentally
effective QELRO must be based on a consistent approach to estimating
emissions in the reference year and in the budget period.as this
would not provide any means of measuring and including improvements
in sinks in QELROs. 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?
The IPCC Guidelines for national inventories recognise varying
levels of uncertainty. The guidelines require that uncertainty
assessments be made for each major part of the inventory. This is
part of the transparent approach to presentation of national
inventories.
Uncertainty is inherent in estimations of GHG emissions and sinks
from all sectors and is likely to remain higher for sectors involving
biological processes than for essentially industrial
areas.
However, using the same methodology over an accounting period
(uniformity of approach) provides a 'consistent' measure acceptable
for QELROs whatever the sector or level of uncertainty. Though
uncertainty in the assessments for individual years may be high,
there is greater confidence in the difference in net emissions over a
given period. A consistent approach to estimates in the base year and
in the budget period provides an acceptable means of assessing the
trend over time.
Australia considers that it is not necessary that the same
methodology apply between countries, only that methods are applied
consistently within a country and across a budget period in
QELROs.
Some methods may not be appropriate to conditions in all
countries.. 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. Hence, the
confidence criteria are more stringent for the energy sector than for
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% |
Australia expects the uncertainties in estimates of both sources and sinks to reduce as refinements in data occur over time. For example, through refinements in developing the 1995 inventory, Australia has already reduced the uncertainty in the rate of land cleared from 50% to 30 % and in the biomass per hectare from 50% to 40%, compared to earlier estimates.
b) What uncertainty levels would be appropriate for sinks
in a QELRO, bearing in mind the uncertainties associated with
sources?
See response to 8a) above. While there are uncertainties
associated with the definition and measurement of sinks, in
Australia's view, there are adequate methods available, if rigorously
applied, to accommodate current uncertainties and enable sinks to be
included in a QELRO.
Biological sectors are both sources and sinks. Estimates of
sources in these sectors are also subject to uncertainty and are
dependent on some of the same information that is used in estimating
sinks. The same rigorous application of methods is adequate to
accommodate uncertainties in emissions sources as well as
sinks.
c) How should uncertainty be dealt
with?
See response to Q8 a) above. The IPCC Guidelines for national inventories recognise varying levels of uncertainty. The guidelines require that uncertainty assessments be made for each major part of the inventory. This is part of the transparent approach to presentation of national inventories.
In Australia's view, these accepted IPCC Guidelines provide a
standardised approach for dealing with uncertainties. In addition,
there is good evidence to demonstrate that improvements in
methodologies and data have already resulted in substantial
improvements in the level of confidence in some areas and there is
every expectation that improvements will continue to be
made.
9. Should there be a limit on the amount of sinks in a
QELRO; if so how should it be determined?
Australia does not support a limit on national sinks in QELROs.
All national sinks relevant to a country's emissions profile should
be included. A comprehensive approach to QELROs enables countries to
develop activities, including protecting and enhancing sinks, that
best reflect their national circumstances and emissions
profile.
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
communications require data on all sectors and on both sources and
sinks. In Australia's view, the accepted IPCC Guidelines provide a
standardised approach for dealing with uncertainties in inventory
data. This is part of the transparent approach to presentation of
national inventories. The review process that is required by the IPCC
guidelines for national communications provides an important means to
verify the data.
11. Should any 'national system' established under Article
4 [Article 5 in the latest draft] give special consideration to
sinks?
Australia views inclusion of 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 the Climate Change Convention and the
Berlin Mandate. Accordingly, as sinks are specifically included,
Australia considers that no 'special consideration' should be given
to sinks in the 'national system' and that removals by sinks should
be regarded as equivalent to reductions in source
emissions.
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 supports a comprehensive approach, covering all
greenhouse gases and all emissions sources and sinks (see Q1 and Q3).
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 sees no need for specific definitions to be included in
the protocol in relation to sinks. The IPCC Guidelines provide a
working definition of 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".
These IPCC guidelines form an integral part of the guidelines for
national communications and have been adopted by the Conference of
the Parties.
14. Do you have any other approach to
propose?
No comment.
15. Do you have specific protocol
language?
No comment.
Question 4: Anthropogenic sinks - Remove "aimed at" and definition
should read "Direct human activities undertaken after 1990 that
protect and enhance sinks capacity, (specifically reforestation and
afforestation) and that affect carbon stocks (deforestation and
harvesting) and that can be verified.
Question 7: Reference Year response for Canada in table is incorrect - emissions 1990, and for net sinks the beginning of the budget period - For your info the difference with our approach and NZ approach is that only net sinks resulting from direct human activities undertaken after 1990 would be included.
1. Regarding the exclusion of sinks at least for the
first budget period.
Parties in this group including Nauru, the Marshall Islands, Japan
and Kenya, mostly cite uncertainty as the reason why sinks should not
be included at this time. In particular, the concern is expressed
that the uncertainty surrounding data in the land use change and
forestry sector will make it difficult or impossible to evaluate
whether key Parties are in compliance with their QELROs.
In New Zealand's opinion, the undeniable fact of uncertainty and
lack of absolute comparability in Parties' inventory reports to date
has to be seen in a broader context. We accept these Parties
legitimate expressions of concern about the impacts of climate
change. But is excluding sinks the correct way to protect the
atmosphere and to reduce uncertainty?
No Party who proposed excluding sinks for now has addressed the
point that exclusion would mean the total of Annex I Parties' QELRO
budgets would be established at a level approximately 10%
higher than if sinks are included (for the same % reduction
target). By contrast, establishing the aggregate Annex I target on a
net basis precludes the possibility of subsequent increases in net
emissions to the atmosphere (within the confines established by
reporting, review and compliance mechanisms). This is a critical
point in terms of the ultimate objective of the Convention -
protecting the atmosphere.
In New Zealand's opinion, to protect the atmosphere we must
constrain the total of Annex I budgets on a net basis. We must also
ensure that Parties take their inventory monitoring and reporting
commitments seriously. To help them in this endeavour we must direct
the necessary attention and resources to methodological issues that
need to be resolved.
New Zealand believes this is most likely to occur by including
sinks within legally binding commitments, not excluding them. There
is a reasonable period of time available before even the earliest
proposed budget periods. Accordingly, there is reason to believe that
with this impetus Parties will be in a position to provide acceptably
accurate data by the time budget periods begin. Compliance
consequences are proposed in the Protocol to deal with Parties who
fail to do this.
New Zealand further notes that the uncertainty issue arises in
respect of a range of other gases and sources. It is not unique to
sinks.
2. Regarding those wishing to include sinks but who don't specify how targets should
be established.
Parties in this group include Canada, Denmark (?), the EU and
Iceland. As noted above, to not be clear about how to address sinks
in setting targets, or alternatively to be clear that it is a "gross"
target, fails to address the need to establish firm budgets based on
net emissions. Setting targets on a gross basis would lead to an
"emissions loophole" as the sinks that existed in 1990 "grow up" and
the rate of CO2 removal from these sinks diminishes to
zero. Depending on exactly how removals by sinks are to be recognised
in a budget period, the emissions loophole could be immediate or
occur over time. But it must occur.
3. Regarding the inclusion of sinks but with a limit on the amount of credit for
removals during a budget
period.
Parties in this group include Canada, Denmark (?), the EU, Iceland
and Peru. In New Zealand's view the overarching principle should
always be "assessment from the perspective of the atmosphere". New
Zealand proposes that all anthropogenic emissions by sources and
removals by sinks should be accounted for in determining if Parties
are in compliance with their QELROs. This is what the atmosphere
"sees". The atmosphere, for example, does not distinguish between a
removal by a sink activity that began before 1990 as compared with
one started after 1990.
We question whether Parties proposing limits to the recognition of
removals by sinks have fully considered the practical ramifications
of such an arbitrary and artificial limitation. The incentive
framework and assessment requirements are made fundamentally
different by drawing such a policy line.
If, for example, forest growers do not gain credit in a budget
period for removals by sinks begun before 1990, does this mean they
should not bear any responsibility if they harvest or otherwise
remove these sinks and then don't replace them? Would this not set up
an incentive to liquidate an existing forest asset and simply shift
activity to a new site which would get credit?
Consider the transaction cost implications of a credible and
transparent system that has to deal with a boundary line between
those anthropogenic removals that are to be counted and those that
are not. This would require case-by-case analysis and scrutiny. These
costs would be borne, inter alia, by the IPCC and their
working groups in establishing the methodologies, all those
participating in SBSTA and COP deliberations associated with these
methodological issues, the secretariat in their role, the Parties
(and companies within) in establishing and maintaining the markedly
more complex inventory systems necessary and the review teams and all
those involved in compliance assessments and processes.
4. Regarding the `discounting` of the amount of removals by sinks because of data
uncertainty.
Parties in this group include Canada and Nauru.
As a general point, New Zealand notes that the uncertainty issue is not unique to sinks.
Data uncertainties for some sources of methane and nitrous oxide are more uncertain than
many Parties' estimates of removals by their sinks.
Discounting is one proposed solution to avoid the circumstance that the atmosphere in
fact sees higher total emissions than is estimated by the use of central values. For
example, under a discounting approach; a central estimate 100 unit CO2 removal credit
may only be counted in the inventory as 75 units if the data certainty was ± 25%.
(Presumably if applied to uncertain gases, they would be counted in the inventory as 125
units in an equivalent circumstance).
New Zealand's views/questions on the treatment of uncertainty in the Annex I Party
Inventories of emissions and removals that will form the basis of assessing compliance
with QELROs are:
are to accept the arguments for uncertainty discounting, this should mean that
inventory data for all emissions should be adjusted to the upper end of the range of
uncertainty and all removals data to the lower. This is for calculating inventories in
the budget period. (Should the reverse be true in the base year? ) We question
whether Parties would ever agree to such a
suggestion.
For agreed inventory methodologies there should be equal probability that the true
value lied on one side of the central point as the other. There is then no logical basis
for preferring a lower to a higher figure.
potential for systematic bias in the way data has been estimated using the chosen
inventory methods.
inventory methodologies that are less certain than an agreed best method, such data
should be adjusted accordingly (ie in a direction that penalises). New Zealand
supports this proposal contingent upon an acceptance that Parties may use better than
"agreed best methods " (IPCC 1996 Inventory Guidelines allow and recommend that
national best methods be used where default methods would
be less accurate).
methodologies and continual improvement in Parties' use of them: the objective
should be to have the most accurate possible
inventories.
The answer to question 1 should be:
Yes, if they are adequately established with sound methodologies, fully recognized.
1. We support inclusion of sinks in QELROs/emission budgets. We support the
approach that emission budgets will be based on net aggregate
anthropogenic carbon dioxide equivalent emissions of greenhouse
gases. Under net aggregate anthropogenic emissions we understand
anthropogenic emissions minus anthropogenic sinks.
2. Inclusion of anthropogenic sinks in QELRO, national plans and policies in the
Russian Federation will provide carbon sequestration for 10-year
period from 2000 to 2010 about 50 millions tons C per year. It seems
to us to be a significant contribution to the balance on GHG
concentration in the atmosphere.
3. High efficiency of measures on anthropogenic sinks, reflection of real possibilities to
increase anthropogenic sinks, valuable global effect on carbon
dioxide concentration in the atmosphere.
4. Sinks caused by clear and concrete anthropogenic measures with clear determination
of baseline.
5. Any commitments should be based on up-to-date scientific data, therefore currently
such guidelines are the IPCC Revised Guidelines, in future it will
be possible to use new revised versions.
6. All categories might be included in QELROs, for which may be provided high
certainty, monitoring and verification.
7. We consider that for QELROs a base year for sinks might be
1990.
8. For anthropogenic sinks uncertainty might be of about 10%, only sinks with low
uncertainty (10%) can be included in commitments.
9. No limits (except uncertainty level).
10. In general, yes, but with further developments, corresponding to new requirements of
certainty and verification.
11. Yes.
12. We consider that Parties should have rights to choose measures (activities) by
theirselves to archive compliance.
13. A definition of "anthropogenic sinks" might be included to
Article 1.
14. Our approaches were presented in proposals of the Russian
Federation to a Protocol.
15. No.
1. Anthropogenic sinks should be eliminated from QELRO due to the great uncertainty
in the sinks classification: anthropogenic or natural ones. For
example, it should be defined how to consider the marshed areas,
forest areas where there is no economical activities and how to
divide or tropical forest into sectors subjected to anthropogenic
activities and not-subjected ones.
2. Due to the absence of the traditional reservoirs of sinks in our country, including or
elimination of sinks at QELRO level in the national plan will play
a significant role.
3. Anthropogenic sinks present absorption by the reservoirs used for the anthropogenic
activities. For example, the restoration of the land use in the
result of anthropogenic activities, making of the artificial water
bodies.
4. We agree with the proposition "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".
1. In order to make these submissions available on electronic systems, including the World Wide Web, these contributions have been electronically scanned and/or retyped. The secretariat has made every effort to ensure the correct reproduction of the texts as submitted.