6 May 1999

ENGLISH/SPANISH ONLY

UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE

SUBSIDIARY BODY FOR IMPLEMENTATION

Tenth session

Bonn, 31 May - 11 June 1999

Item 4 (c) and (d) of the provisional agenda

1. At its fourth session, the Conference of the Parties, by its decision 12/CP.4, requested Parties to submit their views to the secretariat by 31 March 1999 on the consideration of communications from non-Annex I Parties, as well as the timing of second national communications, taking into account Article 12.5 of the Convention, for consideration by the Subsidiary Body for Implementation at its tenth session (FCCC/CP/1998/16/Add.1, decision 12/CP.4, para. 6).

2. Ten such submissions have been received.⁽¹⁾ In accordance with the procedure for miscellaneous documents, these submissions are attached and reproduced in the language in which they were received and without formal editing.

Paper No. Page

1. Alliance of Small Island States (AOSIS) 3

2. Australia 5

3. Chile 8

4. Germany

(on behalf of the European Community and its member States) 10

5. Georgia 13

6. Mexico 14

7. Philippines 15

8. Uzbekistan 19

9. Switzerland 20

10. United States of America 22

The Alliance of Small Island States (AOSIS) is grateful for the opportunity to comment on the issue of the consideration of communications from non-Annex I Parties. As all AOSIS Members are non-Annex I Parties, and the majority are in the process of completing their national communications, this issue is relevant and timely.

I. General concerns with the national communications

AOSIS has found that the assistance provided to them in the preparation of their national communication could be enhanced. A number of technical issues have been raised as particularly difficult for many of the Small Island Developing States to adequately report on. The process of consultations required has also been identified as being far too ambitious for the purposes of the national communications, and to ensure that the contents are as accurate as possible. There have also been difficulties in using some of the existing IPCC guidelines because of issues of scale, as for example emissions from Small Island Developing States in many cases are so very small.

II. Improvements to the guidelines

At this stage, although improvements will no doubt be needed, AOSIS finds it to be premature to call for a full review of the existing guidelines for non-Annex I communications, as contained in decision 10/CP.2. However, AOSIS will engage in the discussions as more and more communications become available to see where any common difficulties have arisen.

III. Consideration of the national communications

AOSIS is of the view that the national communications from non-Annex I Parties should not simply be aggregated for purposes of assessing global emissions figures. AOSIS is of the view that a large amount of additional information will be provided by the non-Annex I Parties in their communications on issues such as adaptation projects, vulnerability assessments and other considerations. AOSIS expects the Secretariat to extract these relevant sections for inclusion in the background documentation for a number of discussions by the Conference of the Parties. These include articles 4.3, 4.4, 4.5, 4.8 and 4.9, as well as 5 and 6. AOSIS Members intend to include information relevant to these issues in their communications, although the initial communications may not cover all the necessary details. Subsequent communications would be gradually improved.

In their national communications, AOSIS considers it to be particularly important for the most vulnerable countries to identify adaptation needs and requirements, and as far as possible suggest projects to assist with adaptation. There should be an opportunity to discuss the proposals first of all in terms of their structure (engineering, further research, etc.), second in terms of technological and innovative dissemination, and third in terms of the financing of these projects. AOSIS sees this as an important part of the process, so that the ideas being generated in one vulnerable country can be shared with others in a similar situation. This would be a meaningful contribution towards implementing article 12.4.

In terms of the exact process that this consideration will take, AOSIS finds it difficult to make a concrete suggestion in the absence of more national communications from non-Annex I Parties. It is at stage considered premature to apply the same review process which Annex I Parties have to take part in to the non-Annex I Parties. However, there are some lessons that could be learned, such as the mutual benefits that accrue from having the advice of experts on sections of a Party's national communication. Whether this expertise should be made available on a voluntary basis, and whether it should be made available prior to the completion of the national communication, or prior to the initiation of the subsequent national communications, is not yet decided. AOSIS considers that at the very least the initial process should also consider issues such as technological needs, capacity building and institutional strengthening identified by non-Annex I for adaptation as well as mitigation measures.

AOSIS would suggest that an initial process be considered for those communications that will have been received by the 5th Conference of the Parties, but that the formal decision should be taken at the 5th Conference of the Parties. This initial process should consider such issue as the need for provision of expertise, enhancement of the reporting structure, policy advice, and problems encountered. The initial process should also highlight how the contents of the national communications can and should be utilized in the discussion of other important issues before the Conference of the Parties. It is also important to facilitate the retention at the national levels of key personnel involved in the production of the national communications. This aspect should be discussed in the context of this initial process, especially in relation to the funding requirements as identified in article 4.3, keeping in mind the provisions of article 12.5 and the ability of the non-Annex I Parties to engage in these activities.

AOSIS looks forward to further discussing these issues at the meetings of the subsidiary bodies in Bonn in May and June, 1999.

Introduction

Australia acknowledges the efforts of non-Annex I Parties to provide their national communications on time. We note the secretariat's advice that nine Parties have now submitted communications, a further 46 communications are expected in 1999, and the rest in the years 2000 and 2001.

Australia welcomes this opportunity to provide views noting that this issue was not settled at the fourth Conference of Parties (COP4). We note that the consideration process for non-Annex I national communications is on the draft agenda for SBI10.

National Communication Preparation Cycle

Australia considers the preparation of national communications for all Parties as a cyclical process, where each cycle has a three to four year duration. The cycle can be described as having three phases: the preparatory phase; the communication phase; and the consideration phase.

The preparatory phase includes establishing an organising framework to ensure that relevant inputs to the requirements of national communications can be fulfilled, as required by the Convention and relevant COP decisions. This framework would establish processes that initiate the collection of relevant data and the engagement of the relevant domestic arms of government and various stakeholders. For instance, a key step in this phase would be the development of national greenhouse gas inventories. In the case of non-Annex I Parties, this phase might also include an early identification of capacity building needs and requests for assistance. Parties may wish to identify possible avenues for addressing these needs, including through multilateral and bilateral channels.

The communication phase involves the collation of climate change information against the relevant national communications guidelines. National communications provide a valuable opportunity for Parties to identify and outline their national circumstances, as well as to identify financial or technological needs that will support their implementation of the Convention, especially potential emission limitation and adaptation projects.

The consideration phase involves an opportunity to evaluate the national communication preparation cycle, assess overall progress towards meeting the objective of the Convention, as well as identifying those areas in domestic capacity that need strengthening. We view the consideration process as a very useful means for Parties to obtain helpful and non-confrontational feedback on their national communications, as well as for all Parties to

obtain greater understanding of individual circumstances and approaches. For its part, Australia has benefited greatly from having its national communication reviewed. While all of the phases are important, Australia sees particular opportunity for non-Annex I Parties to benefit from the consideration phase.

Consideration Process

Australia considers that the emphasis of the consideration process should be on capacity building and information sharing.

We consider that the mechanism of regional workshops could be an efficient and effective method of building capacity amongst non-Annex I Parties. We note that participants agreed that the SBI Workshop on the process for consideration of Non-Annex I Party Communications, Kuala Lumpur, 3-4 August 1998, was very useful. The consideration process could be based on a similar approach.

For example, the Chairmen of the FCCC Subsidiary Bodies could be tasked to design a workshop structure that maximised the opportunities for capacity building and information sharing that involves all Parties of a region exchanging views in a facilitative and supportive manner. Priorities could be inventories and policies and measures. The consideration process should also focus on identifying the most efficient and economic ways of supporting the reduction of emissions through technology transfer and financial assistance. Other issues include research and monitoring of climate change. Given this focus and to emphasise their capacity building nature, participants would most appropriately be technical experts. We expect that the Secretariat's compilation and synthesis report of communications from non-Annex I Parties could be a very useful input to regional workshops, as well as its listing of projects that could limit greenhouse gas emissions.

Australia envisages that one outcome of a workshop in its region might be the identification of possibilities for it to explore assistance with neighbouring Parties in the preparatory phases of their national communications cycle, including on technical matters relating to inventories. We would also anticipate that further proposals to facilitate reporting in a transparent and comparable manner will arise.

Timing of Second National Communications

Australia considers it important that all phases of the first cycle of national communications preparation should inform Parties in preparing their second national communication. We would encourage non-Annex I Parties who have completed their first National Communications to contribute to the consideration process and preparation of revised guidelines for second national communications. We consider that there are likely to be many valuable lessons that will arise through the consideration phase of first national communications from non-Annex I Parties. Given the experience of Annex I Parties, we

would expect a consideration of national communications guidelines to take place prior to the

communication phase of non-Annex I Parties second national communications. We note that the COP4 decision on guidance to the GEF anticipated that further advice with respect to second national communications would be provided by the COP.

Australia envisages that second national communications would be submitted on 3-4 year cycles after the submission of first national communications. We note the large divergence in the timing of the submission of first non-Annex I Parties national communications. Parties may wish to consider greater synchronisation for second national communications through the establishment of a common reporting date.

Tomando en consideracion lo senalado en el Articulo 12.5 de la Convencion de las Naciones Unidas sobre Cambio Climatico, asi como lo establecido en la Decision 12/CP.4 para las comunicaciones nacionales de los paises en desarrollo, el Gobierno de Chile viene en senalar lo siguiente:

1. El objetivo de preparar la primera comunicacion nacional es cumplir con el Articulo 12 de la Convencion, en aquellos parrafos que involucran a las Partes en desarrollo. Por ello, el ejercicio de preparar dicha comunicacion -actualmente en curso-lo queremos conducir no solo hacia informar de los resultados del inventario de gases de efecto invernadero y de los analisis de mitigacion y de vulnerabilidad a los impactos del cambio climatico, sino que esperamos establecer en sus conclusiones, nuestras necesidades de capacitacion, de financiamiento-tanto interno como de cooperacion bilateral y multilateral y de proyectos y acciones especificas que permitan ayudar a implementar las politicas y medidas de adaptacion y mitigacion que podamos identificar.

2. Creemos que es importante promover al mas alto nivel de decision politica del pais los resultados y alcances de este primer ejercicio de diagnostico, a objeto de obtener el apoyo necesario para continuar con esta actividad. Sin este apoyo, la capacidad tecnica e institucional que se esta generando no tendra proyeccion en el tiempo, y con ello, el cumplimiento de compromisos futuros bajo el marco de la Convencion se dificultara.

3. Nos parece relevante propiciar la inclusion en un plan o estrategia nacional en cambio climatico de un programa para la actualizacion periodica de futuras comunicaciones nacionales, y a su vez, que dicho plan de accion se inserte en la politica ambiental del Gobierno, asi como en los diferentes planes de desarrollo del pais. Con respecto a este punto, estimamos que el tiempo transcurrido entre la primera comunicacion y las subsiguientes para los paises no Anexo-1, deberia ser al menos de dos anos, con el fin de no desperdiciar la capacidad tecnica e institucional generada actualmente, y de continuar mejorando los resultados de implementacion de la Convencion. No obstante este deseo, la actualizacion de nuestras comunicaciones estara sujeta a la disponibilidad de fondos y asistencia

tecnica, los que deberian ser proveidos en primera instancia por el mecanismo financiero de la Convencion.

4. Referente al tema de las visitas de expertos durante el proceso de elaboracion de las comunicaciones, pensamos que no es aconsejable en esta primera etapa, respetando asi las razones que varios paises en desarrollo han expresado en las diferentes reuniones de la Conferencia de las Partes. Sin embargo, estimamos que un proceso de post-revision por expertos seria muy constructivo, tanto a nivel interno como para fines de intercambio de informacion entre los paises, pero siempre y cuando la Parte en desarrollo que asi lo deseare, haya presentado previamente su comunicacion a la Secretaria de la Convencion. El dialogo que se inicie luego de esta etapa de asistencia posterior, sera muy importante para comprender los alcances de un proceso de revision como el senalado. Al menos asi ha ocurrido con

las revisiones de las comunicaciones de los paises del Anexo 1, en las cuales han participado expertos chilenos.

5. Respecto a la necesidad de obtener capacitacion tecnica, consideramos muy importante que esta sea entregada, ya sea a traves de la Secretaria de la Convencion, del GEF o de otras instancias facilitadoras. Una forma podria ser la realizacion de talleres de expertos en los que se discutan e intercambien puntos de vista acerca de las comunicaciones nacionales, o se compartan tanto a nivel Regional como nacional los problemas encontrados en la elaboracion de la comunicacion. Estimamos que ello podria servir, ademas, para que los paises que no han iniciado aun el proceso de preparacion de sus comunicaciones por diversas razones, puedan contar con mayores antecedentes en esta materia.

6. Referente a la elaboracion de nuevas guias para las comunicaciones nacionales de los paises en desarrollo (PeD), el universo de PeD que ha presentado sus comunicaciones es bajo hasta ahora, lo que lleva a pensar que resulta prematuro adoptar una decision para la elaboracion de nuevas guias, distintas a las aceptadas en la COP2 para esas Partes. Se sugiere, por tanto, posponer una decision en tal sentido, y que las Partes menos desarrolladas utilicen las guias actuales con el alcance y profundidad que estimen convenientes hasta que un numero importante de dichas Partes haya tenido la oportunidad de realizar el ejercicio a que nos hemos referido.

7. Finalmente, quisieramos destacar que Chile ve las comunicaciones nacionales como un primer paso para apoyar la formulacion de sus politicas y medidas nacionales para enfrentar el problema de cambio climatico. Por ello, un analisis en profundidad acerca de la importancia de las comunicaciones nacionales, nos lleva a visualizarlas no solo como una herramienta de diagnostico de nuestra situacion en materia de cambio climatico, sino tambien como un instrumento para fomentar la toma de decision en estas materias, y para ayudar a la Conferencia de las Partes a identificar las necesidades que los paises en desarrollo tienen en estas materias.

Germany on behalf of the European Community and its Member States submits views on the consideration of national communications from non-Annex I Parties as well as the timing of second national communications, taking into account Art. 12.5 of the Convention.

In general, the EU sees considerable benefits for developing countries through the national communications process. Multilateral and bilateral donors need a basis on which to invest in climate friendly technologies and this can best be provided through national communications which detail non-Annex I country programmes in particular for the mitigation of climate change and their needs to facilitate adequate adaptation to climate change. The EU notes that considerable advances have been made recently which increase the need for timely information. For example, agreement at COP4 to fund adaptation measures (Stage II activities) and to enhance capacity for the transfer of technologies both require information on recipient country government priorities.

I. Consideration of national communications from non-Annex I Parties

The EU believes that the consideration of the information contained in the national communications from non-Annex I Parties is essential in order to make progress in other areas of the Convention. The EU reiterates the need for an efficient process given the large number of communications. The EU also believes that the consideration process would contribute to strengthening the implementation of the Convention, e. g. with respect to technology transfer and capacity building. It would inter alia contribute to the refinement of specific technical and capacity needs. The EU believes that a decision on the consideration process should be taken no later than COP5.

In addition, non-Annex I Parties could also benefit from regional workshops or other effective arrangements. Here specific regional common issues could be dealt with at expert level. This approach could facilitate exchange of experiences and more specifically, the identification of capacity building needs. This could further assist these Parties in implementing their commitments under the Convention.

In the view of the EU, the consideration process should include the following elements:

1. The purpose of the consideration process should be to assess, in a facilitative, non-confrontational, open and transparent manner, the information in the initial national communications from non-Annex I Parties in order to enable the assessment of the implementation of the Convention by these Parties, in particular their commitments under

Art. 4.1. The arrangements shall also enhance the comparability and focus of national communications from non-Annex I Parties and assist the Secretariat´s determination of needs of non-Annex I Parties for the preparation of their initial national communications in accordance with Art. 8.2c;

2. Initial national communications submitted by non-Annex I Parties should be subject to an expert assessment carried out by expert teams under the authority of the SBI;

3. The expert teams should be coordinated by a representative of the secretariat and be composed of experts selected from those nominated by Parties and, as appropriate, by intergovernmental organisations;

4. The expert teams should conduct their work through „paper" assessments, guided by the purpose of the assessment referred to in para 1 above;

5. On the request from a Party, an in-country expert assessments should be arranged;

6. Each expert team should produce a report on assessment of an initial national communication, written in a non-confrontational manner, and submit it to the SBI for its consideration;

7. Parties and intergovernmental organisations should be invited to contribute to the consideration process by nominating experts for selection to participate in the expert teams;

8. The Secretariat should be requested to coordinate the consideration process and to select, under the guidance of the Chairmen of the subsidiary bodies, the members of the experts teams from among the names provided by the Parties and intergovernmental organisations;

9. The necessary arrangements to finance the consideration process from the budget of the secretariat should be made.

II. Timing of second national communications from non-Annex I Parties

The EU suggests that national communications from non-Annex I Parties should be submitted on a regular basis, at intervals of 4 to 6 years, with the exception of least developed countries who should make their national communications at their discretion. With respect to the timing of second national communications, the EU believes that these should be submitted from early 2002 onwards, taking into account Art. 12.5 of the Convention. Revised guidelines for the preparation of national communications from non-Annex I Parties could be adopted by COP6.

With respect to the timing of national greenhouse gas inventories the EU recalls that pursuant to Art. 4.1 (a) of the Convention national inventories of all Parties shall be periodically updated. The EU would be in favour of annual submissions by e.g. 15 April of each year, with the exception of least developed countries who should make their national greenhouse gas inventories at their discretion.

In this context, the EU would suggest that a second compilation and synthesis report of communications from non-Annex I Parties should be available before COP 6.

Financial support from GEF or/and other multilateral or bilateral agencies to non-Annex I countries for preparation their second national communications is one of the most important tool for assisting these countries to fulfil their commitments to the UNFCCC, to implement the principles of Kyoto Protocol in their own countries and continue the works started under the initial national communications. It means to improve the GHG data collection process and to create the database, to develop and implement project proposals for reducing the GHGs, elaborated during the initial national communication, to complete and to realize Climate Change National Plan, to prepare the country for participation in CDM.

1. Each non-Annex I country shall make its second national communication and submit it to the COP within two years of the availability of financial resources.

2. Each non-Annex I country could make application to the GEF or other multilateral agencies for financial support to its second national communication immediately after the completion of the initial national communication. It is necessary to prepare application form for the second national communication in which will be reflected the status of preparation of initial national communication.

3. GEF or other multilateral agencies during the review process for funding of the second national communication should take into account the preparation status of initial national communication.

4. It is desirable that the time period between the finishing of the initial national communication and the starting of the second national communication be minimal (no longer than 6 months) which will enable to keep the capacities and teams created during the preparation of the initial national communication.

5. The second national communication from non-Annex I countries should include the issues which were not cleared out in the initial national communication. (e.g. Human Health)

We agree that communications from non-Annex I Parties shall be considered in a facilitative, non-confrontational, open and transparent manner, and also to ensure that issues and concerns identified by non-Annex I Parties in their initial communications are brought to the attention of the Global Environment Facility (GEF) and, through it, as appropriate, its implementing agencies when undertaking the comprehensive review of enabling activities projects.

Mexico as a Party not included in Annex I made its first communication within three years of entry into force of the Convention, we consider that Parties that have already presented their first national communication and plans to make a second one in the near future, or non-Annex I Parties that decides to elaborate subsequent communications, should have the support mentioned in decision 2/CP.4: Additional guidance to the operating entity of the financial mechanism, that decides that in accordance with Articles 4.3, 4.5 and 11.1, the GEF should provide funding to developing country Parties to: meet the agreed full costs of preparing initial and subsequent national communications, by maintaining and enhancing relevant national capacity, that will take into account experiences, including gaps and problems identified in previous national communications.

Also to assist the Parties with studies leading to national programmes to address climate change, compatible with national plans for sustainable development; including activities mentioned in Article 6 of the Convention, such as strengthening and improving national activities for public awareness and education on climate change and response measures.

Finally, we would also like to obtain support for capacity-building through the GEF operational programmes, and to encourage the GEF in the performance of its obligations, as first priority, whenever possible, to use national experts/consultants in all aspects of project development and implementation.

Basis for Action

Decision 12/CP.4 clearly states the basis for action insofar as the matter of consideration of "Initial national communications from Parties not included in Annex I to the Convention is concerned". These are:

1. In paragraph 1. (a) : Article 10.2 (a) of the UNFCCC which states that "Consider the information communicated in accordance with Article12, paragraph 1, to assess the overall aggregated effects of the steps taken by the Parties in the light of the latest scientific assessments concerning climate change;"

Decision 12/CP.4 therefore states in paragraph 3 that the COP decides to request the Subsidiary Body for Implementation, at its 11th session, to consider the information communicated by non-Annex I Parties in assessing the overall aggregated effect of the steps taken by Parties, and in paragraph 4, to request the Subsidiary Body for Scientific and Technological advice to prepare scientific assessments of the overall aggregated effects of measures taken, in accordance with Article 9.2 (b) of the Convention.

It must however be kept in mind that the assessment of the overall aggregated effects will be made on the steps taken by the Parties, and not just non-Annex I Parties. The SBI will then have to take into account not only the relevant information communicated by non-Annex I Parties, but also the relevant information as taken from the communications of Annex I Parties as well, in order to assess the overall aggregated effects of these steps, in the light of the latest scientific assessments of the overall aggregated effects of measures taken in the implementation of the Convention, as stated in Article 9.2 (b) of the Convention.

2. In paragraph 1 (c), that, pursuant to Decision 10/CP.2, in its paragraph 2 (b) the

national and regional development priorities, objectives and circumstances of non-Annex I Parties should, in accordance with Article 4.1 of the Convention (commitments of all Parties) and the provisions of Article 3 (Principles) and Articles 4.3,4.4, 4.5, 4.7, 4.8, 4.9, and 4.10 of the Convention, be taken into account by the Conference of the Parties in considering matters related to their initial communications.

In order therefore, to start to consider in any relevant manner the initial communications of non-Annex I countries, it would be essential to have information on hand as to the status of the implementation of Article 4.1, Articles 4.3, 4.4. 4.5, 4.7, 4.8, 4.9, and

4.10 of the Convention, (all under Article 4, "Commitments), in the light of the provisions of Article 3 ("Principles").

The Philippines consider in particular that this is essential because of the provision of Article 4.7 which states that "the extent to which developing country Parties will effectively implement their commitments under the Convention will depend on the effective implementation of developed country Parties of their commitments under the Convention related to financial resources and transfer of technology, and will take fully into account that economic and social development and poverty eradication are the first and overriding priorities of the developing country Parties. " These elements are closely related to the preparations for national communications, the timing of its submission and its contents, and the context in which any consideration of communications from non-Annex I communications is to be taken, that is, "that economic and social development and poverty eradication are the first and overriding priorities of the developing country Parties."

On Steps to be Taken:

1. Decision 12/CP.2 also states, in paragraph 7 (b), that the COP requests the Secretariat "to compile and synthesize the information provided in initial national communications from non-Annex I Parties, as indicated in decision 10/CP.2..."and again in para. 7 (c) to prepare the first compilation and synthesis report of communications from non-Annex I Parties based on submissions received from Parties by 1 June 1999...", and also in para. 7 (d), to compile and make available to Parties a list of projects submitted by non-Annex I Parties in accordance with Article 12.4 of the Convention. It is therefore clear that the consideration of non-Annex I communications has already started with the compilation and synthesis of the communications received until 1 June 1999, to be used in the assessment as described under "Basis for Action", above.

2. Given, however, the small number of submissions received so far, due to the differentiated timing of submissions in accordance with Article 12.5 of the Convention, the Philippines, together with other developing countries, considers that what is important at this point would be to provide further assistance to developing country Parties, upon request, for the preparation of their communications, in the light of the results of the compilation and synthesis to be provided by the Secretariat to the 11th sessions of the subsidiary bodies and to COP5, on the problems encountered in the use of guidelines for the preparation of initial communications, and on other issues.

The Philippines considers that among the most important things which contributed to preparations of initial communications of non-Annex I Parties are the assistance provided by the Secretariat in putting together the guidelines for these communications, and the workshops conducted by the Global Environment Facility to inform non-Annex I Parties on access to financial assistance for the preparations of these communications, albeit at very modest bases, given the lack of resources. It is recognized that non-Annex I Parties do not have the advantage of having an "Expert Group" such as that available to Annex I Parties to assist them in their national communications, nor do they have an organized, permanent forum such as the OECD, through which they can meet inter-sessionally to discuss these and other relevant matters. The workshops conducted by the Secretariat on specific aspects of the preparations of national communications are also very helpful.

In view of the large number of non-Annex I Parties, and the differentiated timetable of the submission of their communications, what would be most useful at this point would be to exchange information and share experiences among them, and to continue to do so during the whole preparations period.

On Timing of Communications

1. Article 12.5 of the Convention is the basis for action on this point. Decision 10/CP.2 in paragraph 24 of the Annex reiterates that each of the non-Annex I Parties "shall make its initial communication within three years of the entry into force of the Convention for that Party, or of the availability of financial resources in accordance with Article 4, paragraph 3. Parties that are least developed countries may make their initial communication at their discretion."

2. The Philippines considers that the frequency of the submission of subsequent communications are to be determined under the same basis for action. It is for this reason that in Decision 11/CP.2 ("Guidance to the Global Environment Facility"), states in its para. 1 (d) that the GEF should take into account that "the preparation of national communications is a continuing process..."

3. Based on the experience of non-Annex I Parties, however, there is a need to clarify what is meant by the "availability of financial resources in accordance with Article 4, para.3". It is necessary that the effective availability of resources be specified. The Philippines, in the discussions in SBI of the reports of the GEF, pointed out that what is needed is information as to when exactly were the financial resources for the preparations of initial communications made available to non-Annex I Parties. Experiences by non-Annex I Parties, as contained also in their submissions to the COP on this subject, have shown that these experiences differ. The Philippines considers that these experiences demonstrate that the timing of the submissions must be determined within three years of the time that the financial resources are effectively made available to the Party, that is, when the resources are given to it, not when the funding was approved, or even when the funds have been transferred to the implementing agency concerned. Information must be provided by the GEF on this matter.

4. It is also for this reason that the Philippines agreed only very reluctantly, and continues to view with concern, paragraph 1 (d) of Decision 2/CP.4 ("Additional guidance to the operating entity of the financial mechanism") which states that the GEF should provide funding to developing country Parties to "meet the agreed full costs of preparing initial and subsequent national communications, in accordance with Articles 4.3 and 12.5 of the Convention, and decision 11/CP.2, paragraph 1(d) by maintaining and enhancing relevant national capacity, so as to prepare the initial and second national communications... "This makes it extremely difficult to set any timetable for the submissions of subsequent national communications, other than the initial and the second national communications which would depend on meeting the agreed full costs for their preparations. Financing the preparations of subsequent national communications would be subjected to further conditions, including negotiations on "guidance on subsequent national communications".

Any decision on the timing of submissions of communications of non-Annex I Parties would have to await this guidance, and further delay the submissions of these communications. This uncertainty would also endanger the continuity of the action required, and the maintenance and enhancement of relevant national capacities, which would entail further financial constraints on non-Annex I Parties for the preparation of their national communications.

The review of the national communications of non-Annex I Parties should, in our opinion, to a maximum extent, facilitate the progress in the attaining of the ultimate objectives of the Convention and have constructive character.

This report has shown that the problems and difficulties, which the Parties are facing in the process of preparation of their national reports should be comprehensively analyzed and create the basis for the elaboration of the effective means for their overcoming when working on the second national communications. In particular, at present, the developing countries and countries with the economy in transition need the financial and technical support for the establishment of the national process, working out or correction of the national action plans in the field of climate change, their proper presentation in the long-term national plans of the social and economical development, as the effectiveness of this support would define the range and character of the future national measures and policies.

For many developing countries the creation of the institutional facilities for the education, training, collection and distribution of information such as national committees and informational centers is very urgent and timely and defines, in particular, the terms and quality of the preparation of their national communication.

The Republic of Uzbekistan considers that it is possible to define for non-Annex I Parties the three-year period for the presentation of the second and subsequent national communications defining from the date of the first national communications.

In response to the call for comments at the fourth session of the Conference of the Parties concerning the consideration of the national communications from non-Annex I Parties, as well as the timing of their second national communication, Switzerland presents the following views.

1. First of all we think that the national communications and their consideration should not be a controversial matter within the Convention. Both should be considered as a technical process and should be dealt with accordingly.

2. Switzerland has already expressed the view that the national communications of

non-Annex I Parties should be considered with the same quality standards like those of Annex I Parties. Taking into account the views and ideas expressed during the discussions within the Convention at that respect, we are now in a position to make more operational proposals for the consideration of the national communications from non-Annex I Parties.

3. We think that the following elements should be considered with particular attention:

i) inventory of GHG emissions and removals

ii) national and regional programmes containing measures to mitigate climate change by addressing anthropogenic emissions by sources and removals by sinks of all GHG not controlled by the Montreal Protocol

iii) vulnerability and adaptation measures and needs

iv) technology and capacity building needs.

Furthermore, the national communication should give some insight into national strategies aiming to promote sustainable development as well as in projects pursuant to Art. 12.4 of the Convention.

4. Practically seen, the whole consideration process of the national communications should be conducted basically by the Secretariat who could involve, as appropriate, experts from Annex I and non-Annex I Parties. Country visits should neither be obligatory nor excluded, but should only be conducted with the agreement of the Party under consideration or at its request. The participation of experts from non-Annex I Parties to the consideration process should be encouraged as it is a good capacity building opportunity.

5. The compilation and synthesis done by the Secretariat of the information provided in the national communications from non-Annex I Parties should identify, among other issues, comparability problems and provide elements to further improve reporting guidelines. A particular attention should be given to GHG inventories.

6. It is essential to preserve the experience gained through the elaboration of the first national communication, as well as to maintain national networks and other institutional arrangements put in place at that occasion. Hence, in order to take advantage of this dynamics, it seems reasonable to invite those Parties having submitted their first national communication, to prepare for the elaboration of their second national communication, taking into account recommendations and improvements of the reporting guidelines resulting from the consideration process of the first national communication.

7. At that respect, it seems appropriate to hold a technical workshop after COP 5 in order to exchange views and experience and improve the reporting guidelines. This workshop would benefit from the compilation and synthesis done by the Secretariat and from the views expressed by Parties prior and during COP 5 on the different issues related to national communications from non-Annex I Parties. It should make recommendations tending to an uniform reporting format for all Parties to the Convention.

8. Given the fact that non-Annex I Parties are not submitting their national communication at the same time, the consideration of these national communications should be envisaged as a continuous process performed by the Secretariat. This implies that institutional and financial arrangements should be secured by the Convention for this process.

Consideration Process

The decision of the Fourth Conference of the Parties (COP-4) regarding the consideration of initial communications of Parties not included in Annex I represents an important step forward. A compilation and synthesis of communications from Parties not included in Annex I will contribute significantly to Parties' knowledge of climate change and of efforts to address it. At the same time, Parties have a strong interest in sharing experiences in the preparation of initial communications, in receiving constructive feedback on their efforts, and in considering ways to improve subsequent national communications. A compilation and synthesis alone will not be sufficient to help them realize these objectives.

Two other components should thus be included in the consideration process. The first is a technical assessment of the greenhouse gas (GHG) inventories of individual Parties not included in Annex I. Discussions with developing country inventory experts indicate that technical feedback would be extremely helpful in improving the quality of future inventories. A technical assessment would provide this feedback. Because of the large number of Parties not included in Annex I, technical assessment would most efficiently be conducted in Bonn by teams of inventory experts drawn from the Parties. If a Party not included in Annex I desires further consideration of its inventory, it should be able, on a voluntary basis, to request a country visit by a team of inventory experts drawn from the Parties.

Participation on a team of inventory experts provides valuable opportunities to share information and to build capacity. For this reason, these teams should be drawn from experts nominated by Parties, in particular by Parties not included in Annex I.

A forum for the exchange of experiences in preparing initial national communications would provide an important opportunity for Parties not included in Annex I to identify problems encountered in the preparation of these communications, to project resource needs related to the preparation of subsequent national communications and to consider ways to improve subsequent national communications.

Such a forum could be established through regional workshops. Although the secretariat already undertakes many activities, including workshops, to assist developing countries in the preparation of initial national communications, these efforts occur at present before or during the preparation of these communications. There would be value, also, in organizing regional workshops on a post hoc basis for Parties not included in Annex I that have completed and submitted initial national communications.

Timing of Second National Communications

In its guidance to the financial mechanism, COP-4 recognized the importance of maintaining and enhancing national capacity and expertise to prepare subsequent national communications, and directed the GEF to meet the agreed full cost of these efforts. Thus, after completion and submission of initial national communications, it will be important to update GHG inventory information annually, using current guidelines. Moreover, ongoing preparation of GHG inventory information would help to develop and maintain in-country capacity.

A COP-5 decision requesting non-Annex I Parties to update inventory information annually would provide the impetus to maintain this capacity. It would also signal the importance that the COP attaches to this information in carrying out its responsibilities under the convention.

With respect to second national communications, the first compilation and synthesis of initial national communications will provide useful input for considering ways to improve the guidelines so as to enhance the comparability and focus of national communications. For this reason, consideration of guidelines for second national communications of Parties not included in Annex I should begin at the 12th meeting of the Subsidiary Body on Implementation to take into account issues raised in the compilation and synthesis.

We look forward to further discussion of these matters.

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.

FCCC/SBI/1999/MISC.1

GE.99-