5 November 1998

ENGLISH ONLY

UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE

SUBSIDIARY BODY FOR SCIENTIFIC AND TECHNOLOGICAL ADVICE

Ninth session

Buenos Aires, 3-10 November 1998

Agenda item 4

1. In addition to the submissions included in document FCCC/SBSTA/1998/MISC.6

and Add.1,⁽¹⁾ one further submission has been received.

2. In accordance with the procedure for miscellaneous documents, this submission is attached and reproduced in the language in which it was received and without formal editing.

1. Introduction

Japanese Government herewith submits the views on possible approaches to resolving the methodological issues related to GHG inventories. The contents of this paper are classified according to the chapter organization of the Annex in "FCCC/SBI/1997/19" except item 9.

2. Transparency and Comparability

<Transparency>

It is considered that ensuring transparency of GHG inventories is very important and will be indispensable to confirm Parties' legally binding commitment under Kyoto Protocol after 2008.

Keeping GHG inventories transparent is also a current task. Efforts have been made for encouraging Parties to keep their inventory transparent by giving instructions in the IPCC Guidelines and In-depth Review process for National Communications.

While IPCC guidelines request Parties to submit IPCC worksheets or equivalent information, definition of equivalent information is not sufficiently provided. Parties who do not use IPCC worksheets may wonder what is the extent of equivalent information subject for submission. Inclusion of original material for emissions factors, acceptable languages, media (paper, electric information) and configuration of information are important points. Clarification of the extent of information required for ensuring GHG inventory transparency would help Parties for efficient data handling and submissions.

Generally speaking, Parties should keep their inventory transparent even if concrete instruction does not exist. For example, Japan has been making efforts to prepare inventory calculation system by using electric spreadsheets software since 1997. In constructing the system, most calculation processes were transplanted into spreadsheets. This procedure is recommendable because it brings fruitful benefits such as efficient data handling for self-examination and keeping national inventory highly transparent and accountable.

The utilization of spreadsheet software may assure the inventory transparency at data handling/management level. Assuring the transparency in activity data and emission factor data themselves still remains. If Parties are concerned about this problem, discussion should be stared in order to confirm the extent of UNFCCC commitment to verifying activity and emission factor data and data generation process of emission factor.

<Comparability>

Keeping high comparability in GHG inventory is very important to evaluate and analyze Parties' progress of climate change mitigation in a detail way. Definition of source & sink categories and sectoral report table format in the IPCC guidelines are the basis for checking the discordance in category and verifying the degree of breakdown of Parties' inventories. Unfortunately, breakdown of source & sink category is still not sufficient in 1996 IPCC revised Guidelines though the progress was conspicuous from 1995 Guidelines. Preparing sectoral report format with further breakdown of source & sink category is desired. This preparation would give parties the motivation for being conscious with categorical discrepancy in the Guidelines and their inventory and attempting to make their inventory comparable with the Guidelines.

3 Completeness

Basically attaining completeness with full coverage of activity is important and Parties should make efforts to do so to the extent possible. Therefore the Government of Japan has been making efforts to cover emissions and removals from all types of anthropogenic activity since establishment of the national Inventories. In preparing GHG inventory, Parties should be conscious with two kinds of completeness; 1) completeness within a specific activity and 2) completeness within the whole anthropogenic activities.

Regarding the completeness in the second sense, it is needless to say that Parties should make best effort to expand the coverage of GHG inventory. In the same time it is considered to be also important that Parties clarify the following points,

1) Sources & sinks that is not included in their inventories;

2) The trend of emissions and removals of sources and sinks that is not included in their inventories if possible;

3) Reason for the exclusion of specific sources and sinks; and

4) Outlook for the additional inclusion of sources and sinks into their inventory.

It is also desired that criteria for the allowance of exclusion of specific sources or sinks be provided, in order to prohibit arbitrary interpretation of the exclusion of specific sources or sinks Party by Party.

4 Confidence levels

The IPCC guidelines request to use the codes "H, M, L" in order to evaluate the confidence in estimation of GHG inventory. Since these codes do not have clear definition with quantified numbers of error bar and other type of norm in the Guidelines, we were a little confused for the application of the codes and had to define the codes by ourselves with consultation of national experts during the preparation of SNC.

This situation allows Parties to make unique interpretations of the codes so that the codes are not comparable among Parties. In the spirit to attain comparability also in the aspects of confidence levels in estimation of GHG inventories, introduction of clear definition of "H, M, L" with quantified definition in the IPCC Guidelines is essential in longer term. At least, Parties should make effort to clarify their definition and application of the codes before the introduction.

5 Recalculation of the base year inventory

Inventory calculation is a developing process. Since the outcomes of scientific research will be expected to contribute to improving National GHG Inventories in the future, It is neither advisable nor reasonable to stop revising and recalculating GHG inventories. However there might exist the case that new methodology is unavailable due to lack of data in previous years.

While methodological accordance of GHG inventory in 1990 and commitment period become a basic condition to assure the legal binding commitment under Kyoto Protocol.

The problem is that recalculation of inventory from 1990 to latest year will require more and more work in responding to above two conditions at the same time. It is felt that discussion should be initiated among Parties to resolve these problems.

6 The use of global warming potentials (GWPs)

GWPs are key parameters in calculating CO2 equivalent emissions of a Party under the Kyoto Protocol processes. It is desirable that concrete guidance about the application of GWP in FCCC Guidelines on national communication and IPCC Guidelines should be introduced. Further GWPs refinement is also hoped in order to evaluate Parties' emissions more correctly.

7 Emissions from LUCF

Please refer to the submission of the government of Japan, "Information related to the implementation of Article 3.3 of Kyoto Protocol, particularly on data and methods, and questions and issues identified in FCCC/SBSTA/1998/INF.1" and other documents that will be available accordingly.

8 Reporting of other GHGs (HFCs, PFCs and SF6)

In considering the implementation of Kyoto Protocol, each gas species (e.g. HFC-134a, PFC-16) of HFCs and PFCs should be clearly defined at first. Then reporting format and guidance should be elaborated for the Parties' submissions of data of all GHGs to be covered by Kyoto Protocol. Currently the latest IPCC guidelines has no sectoral report format prepared for the data of each gas species in HFCs and PFCs. Breakdown of gas species in reporting format is recommended in the next update of the IPCC Guidelines.

9 Review process for the information submitted under Article 7

Currently national GHG inventories submitted under the article 12 of UNFCCC have not been subject to verification process by independent third parties but in-depth review process for National Communications and self-examination of national inventory experts. This situation is considered to be insufficient for warranting the contents of the communication under article 7 of the Kyoto Protocol. It is considered that efficient and effective guidelines such verification process stipulated in the article 8 of Kyoto Protocol in future are required. The preparatory work should be started as early as possible. Auditory system in accounting field and financial sector might be some help for the preparation work.

1. Previous submissions from Parties on this issue, made in response to a similar request from the SBSTA

at its seventh session (see FCCC/SBSTA/1997/14, para. 16 (a)), are available in document FCCC/SBSTA/1998/MISC.2.

FCCC/SBSTA/1998/MISC.6/Add.2

EZE.98-