3 September 1999

ENGLISH/SPANISH ONLY

UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE

SUBSIDIARY BODY FOR IMPLEMENTATION

Eleventh session

Bonn, 25 October - 5 November 1999

Item 9 (a) and (b) of the provisional agenda

1. The Conference of the Parties, by its decision 12/CP.4, requested Parties to submit their views to the secretariat 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 (FCCC/CP/1998/16/Add.1, decision 12/CP.4, para. 6). Also, at its tenth session, the Subsidiary Body for Implementation (SBI) invited Parties to submit to the secretariat further views and comments, if any, on these matters by 15 July 1999 (FCCC/SBI/1999/8, para. 39).

2. The Subsidiary Body for Implementation requested the secretariat to compile and make available such views and comments for its consideration at the eleventh session of the SBI.

3. 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. Australia 3

2. Chile 6

3. Finland

(on behalf of the European Community and its member States) 9

4. Georgia 14

5. Kenya 15

6. New Zealand 17

7. Sudan 18

8. United States of America 19

9. Uruguay 24

10. Uzbekistan 28

Australia appreciates the efforts of non-Annex I Parties to prepare their initial national communications. We note the timetable for the receipt of initial national communications outlined in document FCCC/SBI/1999/INF.3, and look forward to viewing further national communications in coming months.

Australia has provided views on national communications from non-Annex I Parties in previous submissions. In terms of moving forward on this issue, we believe that the emphasis in assessment and improvement of non-Annex I Party national communications should be upon greenhouse gas inventory data. In this regard, we see a key role for an Expert Group from non-Annex I Parties, and an important need for revisions to the non-Annex I Party national communication guidelines.

Expert Group from non-Annex I Parties

Australia welcomes plans put forward by the Group of 77 and China to establish an Expert Group from non-Annex I Parties. Such a body could make a positive contribution to the ongoing negotiations and provide valuable contributions towards achieving the objectives of the Convention. In particular, such a Group could make useful contributions to progressing work related to national communications from non-Annex I Parties.

An Expert Group from non-Annex I Parties could initially be set up for a period of two years. During this period the method of working and procedures for the Group could be progressively refined.

During this initial phase the Group should focus on

•the assessment of greenhouse gas inventories in national communications from non-Annex I Parties
•the preparation of guidelines for greenhouse gas inventories for second national communications from non-Annex I Parties

Extension of the Expert Group's work beyond the initial phase would be subject to the outcome of a review of progress made. Depending upon the outcome of the review, it would also provide a basis for possible future priorities of the Group. Australia sees additional areas in which an Expert Group from non-Annex I Parties could continue to make useful contributions:

•capacity-building needs related to the development of inventories. This might include an analysis of countries' capacity to adapt IPCC methodologies to national circumstances and to develop regionally appropriate emission factors. In this respect, Australia may have particular expertise to offer, as we have developed a range of detailed emission factors that are suited in many instances to the agricultural, and land use change and forestry, circumstances of many non-Annex I Parties.

•progressing work on vulnerability assessments and adaptation measures,

•identifying ways in which non-Annex I Parties can contribute to the objectives of the Convention, in particular towards reducing global greenhouse gas emissions, and at the same time strive towards achieving their economic development goals.

We envisage that the Subsidiary Body for Implementation (SBI) would establish the tasks, timelines and membership of the Group at the earliest opportunity. Its function, in keeping with the tasks outlined above, would be to provide advice to the SBI for it to make policy determinations on relevant topics. The Group would develop its working methods, which should include the use of experts from the Roster of Experts, as well as from other international organisations. The SBI would receive inputs from the Group and feed these into the Convention negotiations as appropriate.

The Expert Group from non-Annex I Parties could comprise ten members from non-Annex I countries and five members from Annex I countries. All members of the Expert Group would contribute to the Group's work in an equal capacity. We would anticipate that the joint Annex I - non-Annex I membership of the Group would allow the Group to draw upon the widest possible expertise.

Technical assessment

Developing countries have indicated on a number of occasions that improving their capacity in relation to the development of inventory data is a pressing need. The generation of inventory data is the most technically demanding aspect of the preparation of national communications, and in this regard it is appropriate to develop an early focus upon the technical assessment of inventory data.

Revisions to non-Annex I Party national communications

Recalling the timetable for the receipt of initial national communications outlined in document FCCC/SBI/1999/INF.3, it is unlikely that all non-Annex I initial national communications will be received within the next two years. It will be important to press ahead with considering the manner in which the guidelines for second national communications might be revised. It is important to revise the guidelines early to facilitate the preparation by those Parties that have submitted initial communications of their second national communications.

Australia is encouraged by the fact that most non-Annex I Parties that have submitted national communications to date have provided far more inventory information than is required under the guidelines. Thus revisions to the guidelines could have a simple but effective focus. Table II of the current guidelines should be amended to request the sectoral and summary reports (Tables 1-6 and 7A), as well as the uncertainty overview tables (Table 8) from the IPCC revised 1996 guidelines, comprising a total of 18 pages of tables. It would be useful to augment this information with IPCC worksheets, though given the need to update these worksheets this need not be mandatory. The sectoral reports could be revised to ensure that they are as clear to read and easy to complete as possible. It would also be useful to include explanatory text in the revised guidelines, to provide clear and helpful instructions for non-Annex I Parties when filling in these reports.

These new tables would add considerably to knowledge about regional and global trends and emissions. Such tables could reveal areas where Parties have gone beyond default guidelines and developed their own emission factors. Such emission factors may in the future be suitable for use on a regional level, adding further to the accuracy with which world emissions may be estimated.

They would also greatly add to the transparency and consistency of non-Annex I national communications. We note that this is in accordance with several of the principal objectives of non-Annex I national communications as outlined in those guidelines, including:

"(b) to encourage the presentation of information in ways that are, to the extent possible, consistent, transparent and comparable as well as flexible, and to take into account specific national situations and requirements for support to improve the completeness and reliability of activity data, emission factors and estimations;

(d) to facilitate the process of preparation, compilation and consideration of the communications, including the preparation of compilation and synthesis documentation."

Australia considers that this proposal should be considered by the Expert Group from non-Annex I Parties, with a view to finalising revised guidelines for second national communications for adoption at COP-6.

In paragraph 4 (c) of document FCCC/SBI/1999/CRP.6, the Subsidiary Body for Implementation invited Parties to submit further views on the draft decisions submitted by the Group of 77 and China and the European Community on National communications from Parties not included in Annex 1 to the Convention. According to this, the Government of Chile sets out the following views:

On guidelines,

1. Existing Guidelines for the preparation of initial national communications by Parties not included in Annex 1 to the Convention, contained in the Annex to decision 10/CP.2, shall remain valid for all such initial communications. Nevertheless, a decision should be taken by the Conference of the Parties with a view to further enhance the accuracy, completeness, comparability and focus of current non-Annex 1 national communications, in order to prepare guidelines for second and subsequent national communications. This decision should take into account considerable information on the use of existing guidelines by Parties not included in Annex 1, to be obtained from the compilation and synthesis of initial and second national communications, according to decision 12/CP.4.

2. However, non-Annex 1 Parties which may wish to advance actions in an attempt to improve the information and focus of their initial national communication, may use elements from the guidelines approved for Parties included in Annex 1 to the Convention when preparing such initial communications, as stated in paragraph 2 (c) of decision 10/CP.2. Those Parties may likewise do so when preparing their subsequent national communications, if new guidelines for non-Annex 1 communications are not still available;

On timing of submissions of non-Annex 1 national communications and greenhouse gas inventories

3. The timing of submissions of each non-Annex 1 Party's initial, second and subsequent national communications shall differ for each non-Annex 1 Party, according to, primarily, the availability of financial resources and the timing of disbursements provided by the GEF. Even though Article 12.5 of the UNFCCC provides for a differentiated timetable in determining the frequency of subsequent communications, as well as for submissions of first and second national communications from non-Annex 1 Parties, there is a need that the UNFCCC financial mechanism must secure the availability and disbursement of funds to non-Annex 1 parties on a timely manner. This will i) enlarge the current amount of non Annex 1 submissions of initial national communications, ii) enrich the results of the compilation and synthesis of non-annex 1 communications as called for in decision 12/CP.4, and iii) shorten the timing between each subsequent submission of a non-Annex 1 Party´s national communication.

4. Full information from the operating entity of the financial mechanism on the effective availability of financial resources to non-Annex Parties, and the disbursement timing of these resources to developing countries for the preparation of their initial and second national communications would be necessary to determine each non-Annex 1 Party's submissions timing, in accordance with Article 4.3 and Article 12.5 of the Convention;

5. If a Party not included in Annex 1, which is not a least developed country and which has submitted its initial national communication, may wish to submit an annual greenhouse gas inventory update, could do so on a voluntary basis. The resources needed to accomplish this task could be drawn from the GEF, if applicable, or from other sources and means identified and arranged by that Party.

On the review of non-Annex 1 national communications and the provision of technical support

6. Each initial non-Annex 1 national communication should be reviewed and technically assessed in a facilitative, non-confrontational, open and transparent manner, on the basis of decision 10/CP.2. The purpose of these assessments is to analyze the information contained in these communications, in accordance with Art. 12.1 of the FCCC. This would provide

- the COP with accurate, consistent and relevant information to assist it in carrying out its responsibilities after identifying non-Annex 1 Parties needs set out in their national communications (i.e., funding, implementation of projects, technology transfer, etc.);

- Parties not included in Annex 1 with feedback on ways to improve the quality of subsequent communications, to identify gaps of information required by the guidelines for the initial communications and to identify further needs related to the preparation of communications.

7. The technical assessments should be organized by the FCCC secretariat and undertaken by technical experts nominated by Parties, and may, with the consent of the Parties concerned, include country-visits;

8. In order to assist the Conference of the Parties in the provision of technical support to non-Annex 1 national communications, a non-Annex 1 Group of Experts could be set up, on the basis of nominations received from Governments of non-Annex 1 Parties. This Group of Experts would, inter alia, assess the availability of financial resources and technical support, identify gaps, and promote the exchange of experiences and information among non-Annex 1 Parties, with the objective of enhancing support to preparations. The Group would also identify the difficulties encountered by developing countries in the use of available guidelines, so as to improve their national communications.

9. This Group shall meet regularly, and be provided the necessary resources to do so. Results of their meetings, and any recommendations from this Group shall be taken into account by the Subsidiary Bodies in their deliberations, and for any decisions to be taken by the Conference of the Parties on the national communications from non-Annex 1 Parties.

10. The Government of Chile welcomes the initiative of the FCCC secretariat together with the GEF and its implementing agencies to organise workshops and expert group meetings under the National Communications Support Programme (NCSP) which enable Parties to share experiences and information with experts from other interested Parties and to identify barriers and problems encountered in the preparation of communications.

On other technical matters that would improve the scope and completeness of non-Annex 1 national communications.

11. The Intergovernmental Panel on Climate Change (IPCC) Inventory Task Force should give high priority to the development of a work plan to prepare a comprehensive database on emission factors, by region and technology, and to coordinate with the FCCC secretariat regarding this work plan and to report on progress to SBSTA at its 12^th session.

12. In coordination with the IPCC, the FCCC secretariat should facilitate the preparation of a paper on regional priorities for the research and development of emission factors, taking into account the conclusions of the regional workshops, the experiences drawn from the technical assessment of greenhouse gas inventories and inputs from Parties and relevant experts and organisations, and to submit this paper for consideration by SBSTA at its 12^th session.

On GEF funding for further work on non-Annex 1 communications

13. During the deliberation process that should end with the approval of guidelines for second and subsequent national communications, the GEF should provide funding to developing country Parties which have submitted initial communications which have undergone the technical assessment provided for in paragraphs 6 to 9 above

- for the preparation or, as appropriate, the refinement and the reporting of greenhouse gas inventories;

- for further work on local emission factors in accordance with decision 10/CP.2, paragraph 13, and taking into account the activities described in paragraphs 11 and 12 above;

- for further work on the estimation of GHG emissions baseline and abatement assessments

- for developing country Parties which are particularly vulnerable to the effects of climate change, for activities related to the assessment of vulnerability and adaptation options in accordance with decisions 10/CP.2 and 2/CP.4.

1. This submission sets out the European Union's approach to non-Annex I national communications. It is intended to provide some explanation and background to the draft decision submitted by the EU at SBI10. The EU has listened carefully to the views expressed by Parties. We welcome the open and constructive atmosphere in which discussions have taken place and hope that this submission will contribute to that atmosphere.

Timing of initial and second communications

2. Inevitably, given the widely differing circumstances of developing countries and the fact that LDCs have no deadline for completion of initial communications under Article 12.5 of the Convention, it will be some time (perhaps many years) before all initial Non-Annex I communications are produced. In the meantime, a growing number of non-Annex I parties who have produced initial communications will wish to start to move towards production of their second communications. So any process agreed by the COP needs to take account of a differentiated timetable, whereby, in future, some non-Annex I Parties will be in the course of producing their initial communications, whilst other non-Annex I Parties are producing their second communications.

Guidelines for initial communications

3. The EU believes that the guidelines for initial communications set out in Decision 10/CP.2 have served a very useful purpose and will continue to be of great value to those Parties who have still to produce their initial communications. Because of their continuing value we would suggest that they should remain valid for initial communications until the last initial communication has been produced.

Learning lessons: technical assessments

4. The EU recognises the valuable efforts of non-Annex I Parties in producing their initial communications and believes that all Parties could benefit from the lessons learned. We welcome the production of a compilation and synthesis by the Secretariat and believe that it will help this process of lesson learning. We believe however, that the most practical and effective way to ensure the process of lesson learning is an assessment by experts of non-Annex I communications. Such a technical assessment could ensure that problems encountered by non-Annex I Parties are recognised and that lessons learnt are passed on for the benefit of others. These lessons could be valuable both for those Parties producing second communications and those still in the process of producing first communications.

5. It must be emphasized that such assessments would be technical exercises. They would focus on the experience of the relevant non-Annex I Party in preparing their initial communications and would assess problems and questions arising from that process. The Annex to this submission sets out the EU's initial views on the arrangements and methodology of such technical assessments.

6. Experts could be selected by the Secretariat, on the basis of nominations by Parties. We note the proposal in the G77 and China text for a 'non-Annex I Expert Group' and believe that the proposal deserves further careful consideration. Like the G77 and China, we believe that non-Annex I experts should play the major role in this process of lesson learning. But we also believe that the experiences of relevant Annex I experts could benefit the process significantly. Our view also is that any process of expert advice which feeds formally into the COP's consideration of communications should be coordinated by the Secretariat.

7. We note that around 40 initial communications are expected to be produced by the end of 1999. We believe that the technical assessment process should be agreed by COP5, in order to begin the process of lesson learning.

8. Those non-Annex I parties who wish it, should also have access to more detailed analysis of their communications, e.g. by expert visit, subject to resources being available.

Second communications

9. A number of Parties have expressed readiness to start to develop second communications. This number can be expected to grow during 1999 and 2000. The COP needs to prepare a process for facilitating and, in time, considering these (without interfering with the process by which initial communications are prepared).

10. A number of non-Annex I Parties have said that second communications should be an improvement on initial communications, for instance regarding the information provided on national inventories. The EU strongly supports this view and is prepared to listen to suggestions from those countries that are interested in preparing 2^nd communications both of how they propose to overcome obstacles they encountered in preparing their initial communications and what kind of enhanced information with respect to their initial communications they would propose to include in their 2^nd communications. This exchange of views would be helpful towards the revision of initial guidelines. The exact nature of that revision would need to be decided by the COP. In order to ensure that Parties who wish can start the preparation of second communications within a reasonable timescale, we believe that guidelines for second communications should be agreed at COP 6.

11. We believe it important that work on the production of second communications should not begin until revised guidelines are in place. This is because we would be concerned if some second communications were produced under initial communications guidelines and others under new guidelines. This would lead to confusing circumstances for Parties and the COP.

'Interim assistance'

12. At the same time we understand that non-Annex I Parties are concerned that skills built up in the course of preparing initial communications should not be lost in advance of producing second communications. The GEF Council already started to address this issue at the 13^th Council in May 1999. The EU is willing to consider whether further measures are needed to address non-Annex I Parties' concerns. We have therefore proposed the provision of interim assistance for work on inventories, local emission factors and the assessment of vulnerability and adaptation options, to be provided in advance of second communications being begun.

Period between communications

13. We do not have a fixed view, but second communications might be produced 3-5 years after initial communications, with subsequent communications after similar periods.

EU draft decision

14. The draft decision submitted by the EU at SBI 10 is intended to articulate these views. Please note one change to the draft. Paragraph 13 of the draft suggests in its chapeau that, in advance of assistance for second communications, provision for interim assistance should be made available once there has been a technical assessment of the initial communication of the relevant non-Annex 1 Party. The EU heard concerns from Parties about this provision at SBI 10 and, in response to those views, we are willing to amend our position on the conditionality. This could be done by deleting the words 'which have undergone the technical assessment provided for in paragraph 4 above' from paragraph 13.

15. The EU would welcome views on this submission and draft decision. We look forward to seeing submissions from other Parties and to discussing our position further at COP 5, in the light of the various contributions. We are confident that agreement can be reached on a process which is beneficial to non-Annex I Parties and to implementation of the Convention.

Arrangements:

•Responsible for conducting the assessment: Secretariat
•Assessment team should consist of experts for inventory, mitigation, adaptation, capacity building and technology transfer; one expert could cover more than one topic.
•The Expert team should be co-ordinated by a member of the Secretariat or an international organisation
•The Expert team should consist of 3 to 5 experts, the majority coming out of Non-Annex I Party Countries
•Experts should be selected from a roster of experts taking into account their international and regional experience
•Technical assessment should be conducted within 12 months after submission of the national communication (or 12 months after the COP decision on this issue).
•Each assessment should be funded from same sources as review of Annex I-communications.
•Each assessment should be summarised in an individual report, which will be made available to the COP.
•The Secretariat may produce further synthesis reports on the basis of these reports.

Methodology:

How:

•All Assessments should be conducted as desk or paper study
•Where requested by the Party concerned, country visits by the expert team should be made. Where possible, an expert team might work on several countries of one region.
•All information should be assessed on the basis of the information contained in the national communication only and with a view to facilitate an improvement of all relevant information, where needed.
•The information should be assessed with reference to the guidelines for national communications from Parties not included in Annex I.

What:

a) Descriptive part: The assessment shall include a description of the three main categories of information which Parties are required to report under Art. 12.1. of the Convention:
•national greenhouse gas inventories
•steps taken or envisaged by the Party to implement the Convention;
•any other information considered relevant by the Party

b) Recommendation part. The experts shall assess
•key qualitative information and quantitative data points;
•information with respect to the financial and technological needs and constraints associated with the communication of information,
•information with respect to vulnerability and facilitation of adequate adaptation.
•information to the needs on capacity building associated with the communication of information and the implementation of activities and measures as well as the needs for technology transfer.
•information associated with climate change projects and their relation to capacity building and technology transfer.

The Kyoto Protocol constitutes a new stage of development of the Convention. It offers a mechanism which assists the Annex I Parties in achieving compliance with their quantified commitments to the Protocol in a cost-effective way and serves to help non-Annex I Countries in achieving sustainable development. From the year 2000, non-Annex I Parties will be able to participate in CDM which requires a strong and well-organized system for preparation of national inventory of GHGs. This would ensure that the uncertainties regarding activity data are maximally reduced. Such an inventory system should provide for the development of the inventory process on qualitatively higher level necessary to define the parameters for the initiation of CDM. Certainly with the needed financial and technical assistance provided, the second and consequent national communications would be better.

In preparing new guidelines for the second national communication of non-Annex I Parties, we should take into account the wide spectrum of their potential for economic and social development and the differences in national capacities when seeking to remove barriers hampering the preparation of the national communications. It would be reasonable to divide the non-Annex I countries into subgroups and hence we suggest the creation of a different guideline for the non-Annex I countries offering themselves to host CDM projects.

The financial support of the second national communications from non-Annex I Parties should be based on the time table under the Article 12.5 of the Convention as well as the conclusions of the compilation and synthesis report on initial national communication submitted by non-Annex I Parties.

General Concerns

The preparation non-Annex I of country proposals on national communications and all aspects of project development and implementation should be left to national experts/consultants unless a Country Party requests for assistance.

REVIEW OF GUIDELINES

As of the time of this submission, only 10 countries had submitted to the Secretariat their initial national communications. We therefore find a review of the guidelines at this stage premature.

CONSIDERATION

It would not be meaningful for the national communications to be just filed away. They should be examined on issues such as adaptation, vulnerability, technologies needs, capacity building etc. and work start on assistance programmes identified by the Parties immediately. Arrangements should be made for in depth reviews at the request of a Party.

Because of the differentiated timetable of submissions of non-annex I National Communications and the length of time it takes GEF to approve the funds, the consideration in whatever form it takes will take time as more National Communications come and with subsequent communications, it will be a permanent feature in the secretariats duties.

TIMING

The next communication should be three years after a Party has submitted its Initial National Communications and should be subject to timely provision of the necessary funding.

GEF should continue to support national communications and speed up the processes leading to the approval and disbursement of funds.

General Comments

The UNFCCC process is characterized by the Secretariat requesting submissions of Parties' views through their focal points, on various agenda items. This means the National Focal Point has to have the capacity to make such submissions. The number of submissions (if at all) received from developing Country Parties is an indicator of the need for the enhancement of this capacity of the focal point. These focal point have to have in place databases that are networked with their national institutions generating and requiring climate change related information. With National Communications being a continuous exercise, these databases are a prerequisite. Adequate funding is key to successful implementation of enabling activities for the preparation of national communications.

1At its tenth session, the Subsidiary Body for Implementation invited Parties to submit comments on the G77/China and EU texts on "National Communications from Parties Not Included in Annex I to the Convention". The following are New Zealand's views on a number of issues raised in those two texts.

2 National communications provide essential information to help inform both international and national responses to climate change. The first priority is therefore to encourage the completion and submission of first national communications. New Zealand notes that 10 communications have been received by the Secretariat to date. We look forward to the many further submissions expected by the end of this year, and encourage all Parties and relevant institutions to work cooperatively and in good faith to promote the expeditious completion and submission of all outstanding communications.

3 The next step is to establish a system for the consideration of first national communications. This should inform the revision of guidelines to ensure second national communications build upon the experiences of the first, and add to the quality of information available. Some elements that could usefully be included in the consideration process are contained in the two texts. The EU text calls for "technical assessments". The key will lie in the design of any such "assessment" process. It will need to take place in a cooperative, informative, facilitative, and fully interactive way. A "Non-Annex I Experts Group" could form one component of this process. In terms of timing, the consideration process should be designed and implemented expeditiously, starting with those communications already submitted, to allow the timely revision of the guidelines for subsequent national communications.

4 The process of considering first national communications and the subsequent revision of guidelines may take some time. It will be important to establish an interim funding arrangement whereby countries that have completed and submitted their first national communications can improve upon these, continuing the momentum with a sensible work programme. Paragraph 13 of the EU text provides a promising approach in this regard. However, we would suggest that the interim arrangement proceed independently of the consideration process. Making interim funding contingent on the completion of the consideration process risks losing the momentum gained from the completion of first national communications.

5 We look forward to considering the framework document for comparing the two texts to be prepared by the co-chairs for consideration by the SBI at its eleventh session.

The Sudan is honored for the opportunity to respond to matters related to the consideration of the above subject. Sudan is a member of non-annex 1 parties and in the process of conducting and completing its national communication, so it is a good time to express its views as follows:

First: Being an active member of group 77 and China, we indorse the draft decision proposed by the group annex (2) of the above reference document on issues of guidelines, timing of submission of non-annex 1 national communications, financial and technical support and on matters related to consideration of non-annex 1 national communications.

Second: The Non-Annex 1 Group of Experts proposed should be set up in an equitable membership manner taking into consideration regional representations and chances already given to parties in different committees and other institutions of the convention i.e giving the priority to non-annex 1 parties which has not been represented before.

Third: Since most of Non-Annex 1 parties did not submit their national communications a workshop on regional basis is vital to facilitate exchange of experience and identification of capacity building gaps.

Fourth: Further assistance and additional funds to developing country parties are needed to improve their communication in light of problems and gaps encountered in the use of guidelines for the preparation of initial communications. Examples are development of national emission factors and improvement of systematic observation.

The United States has read with interest the proposal from the G-77 and China regarding the creation of an Expert Group on National Communications from non-Annex I Parties. Creation of such a group could greatly enhance the participation of experts from non-Annex I Parties in the FCCC process, and could provide useful guidance to the Subsidiary bodies and to the COP on matters related to national communications from non-Annex I Parties. To this end, we believe that the terms and scope of this group should be clearly defined in order to ensure that the work of the group is relevant to the Convention process and avoids duplication with the ongoing activities or the functions of other groups.

We anticipate that the expert group could provide advice and assistance to the Subsidiary Bodies in four broad areas. The first regards consideration of existing activities and programs - by the Secretariat and other organizations - to facilitate and support the preparation and communication of information by non-Annex I Parties. The expert group could be tasked to identify any gaps in this support, and to consider and recommend ways to better coordinate existing programs and activities to make them more effective and more responsive to the needs of non-Annex I Parties.

The second work area could cover analytic and methodological issues. As many non-Annex I inventory experts have noted, there are some technical problems in the preparation and reporting of greenhouse gas (GHG) inventories which are specific to the circumstances of developing countries. Under this task, the expert group would identify these problems, and prioritize areas where additional analysis or research would be useful in order to improve the quality of future inventories, in particular with respect to data collection, the development of regional emission factors and appropriate inventory methodologies.

Third, the group could be charged with the development of revised guidelines for national communications from non-Annex I Parties. In considering revised guidelines, the group could address both appropriate modifications of existing elements, as well as the need for additional information, such as energy system planning and analysis in relation to sustainable development goals. As a first step, the group could develop recommendations on elements of guidelines for second national communications, as well as the timing of submission of second national communications for consideration by SBSTA/SBI 12. The group could also provide recommendations for the long-term evolution of the guidelines.

Finally, the expert group could be responsible for conducting the technical assessment of GHG inventories from non-Annex I Parties and, as appropriate, other aspects of national communications. The objective of the technical assessment would be to provide feedback to the Party on ways to improve the quality of future inventories, and other aspects of national communications as appropriate. Another useful objective would be identification of innovative methodologies used by non-Annex I Parties in the preparation of their national communications. The expert group's involvement could help to ensure that insight gained through the technical assessment process would inform discussion of other aspects of the expert group's work.

With respect to size and composition, the United States recommends that the expert group composed of experts nominated by Parties with technical expertise in substantive areas related to national communications of non-Annex I Parties; e.g.; GHG inventories, vulnerability assessment, GHG abatement, and adaptation to climate change. In order to facilitate communication between experts, each member's expertise and contact information would be compiled into a database and be made available to other experts and Parties. Additionally, we propose creation of an electronic forum for discussion of specific topics and work elements. These elements would provide the primary means for communication and exchange of information within the expert group, and would minimize the need for frequent or large meetings.

In addition to electronic communication, we believe that it would be desirable to provide for occasional meetings of a small number of experts to consider specific issues and consolidate recommendations to the Subsidiary Bodies. Participation would be limited (18 experts) to ensure efficient completion of work, and would reflect an appropriate balance of experts from non-Annex I (9) and Annex I Parties (6), and other relevant organizations (3). Participants would vary from meeting to meeting, and would be selected by the Secretariat based on the specific technical areas covered by the meeting and the need to promote participation by as many experts as possible over time. The expert group meetings would occur in conjunction with Meetings of the Subsidiary Bodies, so that participants could also attend the FCCC sessions.

The attached terms of reference reflect our proposal for the Expert Group on National Communications from non-Annex I Parties. We look forward to further discussions on this matter at the next session.

Purpose and Tasks:

The Expert Group on National Communications from non-Annex I Parties shall provide a forum for the exchange of experiences and information regarding the preparation and communication of information from non-Annex I Parties with a view to improving the quality of communications from non-Annex I Parties. In particular, the Group would:

a) Identify gaps in existing activities to facilitate and support the preparation and communication of information by non-Annex I Parties;

b) Prioritize analytic needs for the improvement of national communications from non-Annex I Parties, in particular with respect to data collection, regional emission factors, and appropriate inventory methodologies;

c) Identify elements for revision of guidelines for national communications from non-Annex I Parties and options for the timing of these communications;

d) Provide feedback on national communications through a technical assessment process to be coordinated by the Secretariat; and

e) Provide recommendations to the Subsidiary Bodies on these matters.

In conducting its work, the Expert Group should take into account the need to avoid duplication of existing information and activities and the need to promote cooperation between organizations engaged in activities related to the national communications of non-Annex I Parties.

Composition:

The Expert Group on National Communications from non-Annex I Parties will be composed of experts nominated by Parties with technical expertise in substantive areas related to national communications of non-Annex I Parties; e.g.; GHG inventories, vulnerability assessment, GHG abatement, and adaptation to climate change.

Exchange of Information and Experiences

To facilitate the exchange of information and experiences among the Expert Group on National Communications, a database of experts by expertise and region will be compiled and made available on the FCCC Website. This database will be supplemented by an electronic bulletin board to provide a forum for discussion of the specific work elements identified above and any related materials.

Meetings:

Two meetings of the Expert Group on National Communications from non-Annex I Parties will be held in the year 2000, each immediately prior to the meetings of the Subsidiary Bodies. Agendas for the meetings will be developed in consultation with the meeting participants and will be designed to ensure coverage of all work elements identified above.

Meetings will be attended by 9 experts from non-Annex I Parties, and 6 experts from Annex I Parties. Participants will be selected by the Secretariat based on the meeting agenda, as well as the need to ensure equitable regional representation of non-Annex I experts. Additionally, the Secretariat may invite 3 experts from organizations with relevant expertise to participate in the meetings.

Future meetings of the Expert Group on Communications from non-Annex I Parties shall be determined by the Conference of Parties.

Technical Assessments

Following submission, the greenhouse gas inventories of all non-Annex I Parties will undergo individual technical assessments. The objective of the technical assessment shall be to provide feedback to the Party on ways to improve the quality of future inventories, and to identify innovative methodologies used by non-Annex I Parties in the development of the GHG inventory.

The technical assessment will be conducted by a small expert team selected from the database and convened in Bonn. One team would be responsible for assessing all national inventories received within a specified period. The size of the team will be dependent upon the number of inventories to be assessed, but will not exceed 18 experts, with up to 9 experts from non-Annex I Parties, up to 6 from Annex I Parties, and up to 3 from other organizations. Upon request of the Party, a technical assessment by a smaller team of experts (3-6) may occur in-country.

On a voluntary basis, non-Annex I Parties may also request technical assessment of other aspects of national communications, such as methodologies used in analysis of vulnerability, mitigation or adaptation options or projections of future greenhouse gas emissions. Technical assessment of these aspects would provide feedback to the Party on the application of methodologies used and on their consistency with other recommended or approved methodologies.

Each team would produce a report of each technical assessment conducted. A Party shall be provided the opportunity to comment on the draft report of the technical assessment with respect to its national communication. These comments shall be reflected in the team's final report. Reports shall be compiled and made available to all Parties.

Secretariat Support:

To facilitate the exchange of information and experiences among the Expert Group on National Communications, the Secretariat is requested to:

a) Compile a database of technical experts by expertise and region and make this information available on the FCCC website;

b) Explore ways to enhance communication by experts, including through the development of an electronic bulletin board;

c) Cordinate meetings of the Expert Group in accordance with guidance from the Conference of Parties;

d) Cordinate the technical assessment of greenhouse gas inventories submitted by non-Annex I Parties and, upon request by the Party, other aspects of national communications; and

e) Communicate conclusions of the SBSTA/SBI regarding matters related to non-Annex I Communications to the National Communications Support Program, and other relevant organizations.

1 La propuesta de la Comunidad Europea y sus Estados miembros, para que los países que hayan presentado la comunicación nacional inicial informen anualmente la actualización de sus inventarios de gases de efecto invernadero (GEI), no se considera aceptable por lo siguiente:

a) en general, las tasas de crecimiento o decrecimiento de las economías de los países no Anexo I y de sus niveles de emisión (vinculados a las mismas), no varían en forma significativa de un año al siguiente, excepto en algunos casos aislados, puntuales o extremos (conflicto bélico, sequías repentinas, etc.);

b) aunque todavía no está vigente el mecanismo para el desarrollo limpio (MDL) y por lo tanto, se carece de experiencia respecto a los resultados de su aplicación, es muy poco probable que debido a la ejecución de proyectos MDL, en el corto o mediano plazo, ocurra un cambio significativo en los niveles de emisión de los países no Anexo I;

c) parece una contradicción que los países no Anexo I, que hayan cumplido con la comunicación nacional inicial, tengan como respuesta un incremento de obligaciones;

d) desde el punto de vista de los compromisos, se estaría ampliando la categorización de los países no Anexo I: los menos desarrollados, los que han presentado su comunicación nacional inicial y los restantes. Ello debería analizarse cuidadosamente, dado que ese tipo de diferenciación no está previsto por la Convención;

e) se considera que, en lugar de aplicar asistencia en esos países para la realización de inventarios anuales, sería más beneficioso para los fines de la Convención, aplicar ese esfuerzo financiero y técnico en la elaboración, mejoramiento o establecimiento de programas de medidas generales para la mitigación y la adaptación, programas nacionales de abatimiento voluntario de emisiones de gases de efecto invernadero, desarrollo de planes de acción, etc.

2. Con referencia a las directrices existentes y a la orientación a proveerse por la COP, relativas a las comunicaciones nacionales, se manifiesta lo siguiente:

a) aunque las directrices vigentes por la Decisión 10/CP.2, fueron establecidas para las comunicaciones nacionales iniciales de los países no Anexo I, se considera que las mismas son totalmente aplicables a la segunda comunicación nacional de esos países;

b) si bien dichas directrices pueden mejorarse, complementarse, etc. ello no debería constituir un impedimento o un condicionamiento para aquellos países no Anexo I, que quieran elaborar segundas comunicaciones nacionales, de la manera prevista en la primera oración del literal d), numeral 1, de la Decisión 2/CP.4, cuyo final se transcribe:…"a fin de preparar comunicaciones iniciales y segundas teniendo en cuenta la experiencia, comprendidos las insuficiencias y los problemas constatados en anteriores comunicaciones nacionales, y las directrices establecidas por la Conferencia de las Partes. La Conferencia de las Partes impartirá orientación para las comunicaciones nacionales siguientes (Guidance on subsequent national communications will be preovided by de Conference of the Parties)";

c) por otra parte, según lo previsto en el texto transcripto precedentemente, la orientación (guidance) a proveerse por la COP, estaría destinada a las comunicaciones nacionales subsiguientes o subsecuentes (subsequent). De acuerdo con ese texto, por "subsiguientes" debería entenderse "las siguientes a las mencionadas previamente, o sea: comunicaciones iniciales y segundas (en este caso)". Por lo tanto, la orientación a proveerse por la COP, sería aplicable a las comunicaciones nacionales tercera y siguientes;

d) de lo anterior se concluye que, sin perjuicio de que se elabore e implemente la orientación prevista en el final del literal d), del pár. 1, de la Decisión 2/CP.4:

i) nada impide continuar con el proceso continuo de preparación de comunicaciones nacionales (Decisión 11/CP.2, pár. 1.d.), por parte de los países no Anexo I que hayan presentado su comunicación inicial;

ii) los países antes mencionados estarían en condiciones de elaborar su segunda comunicación nacional y de recibir la asistencia del GEF prevista para ello.

3. Respecto a la fecha de presentación de las segundas comunicaciones nacionales, por parte de países no Anexo I, se estima conveniente que la misma se establezca en función del momento en el cual esté disponible la asistencia, a ser provista para su elaboración, de manera similar a lo establecido en la segunda opción del nral.5 del art.12 de la Convención.

1. Referidos al numeral 13 del borrador de decisión presentado por la Comunidad Europea y sus Estados miembros

1.1. Introducción:

Se propone establecer que, mientras no se adopten directrices (guidelines) para las segundas comunicaciones nacionales y de acuerdo con la Decisión 2/CP.4, el GEF debería restringir su asistencia a actividades relativas a inventarios, factores locales de emisión y evaluaciones sobre vulnerabilidad y adaptación, en aquellos países no Anexo I que cumplan con los siguientes requisitos:

a) haber presentado comunicaciones nacionales iniciales y

e) haber tenido una evaluación técnica de la misma (según el numeral 4 de la propuesta que se analiza).

1.2. Análisis y comentarios:

a) la capacidad generada, con los esfuerzos combinados del GEF y del Gobierno nacional, debe consolidarse y mantenerse, a través del desarrollo continuo de actividades de aplicación de la Convención y de cumplimiento de compromisos establecidos por la misma. Para ello es necesario disponer de dichos esfuerzos combinados. Sería muy lamentable perder esa capacidad institucional por falta de uno de ellos.

b) siendo la presentación de información, prevista por el art.12 de la Convención, un proceso de desarrollo continuo (evolving process), como se establece en el apartado d) de la Decisión 11/CP.2 y como se expresa, también, en el propio Notando (Noting) del referido borrador de decisión, no resulta coherente que al mismo tiempo, se proponga interrumpir o interferir en el proceso de países no Anexo I, al condicionar y restringir la asistencia que se les debe proveer para ello;

f) la decisión 2/CP.4 que se invoca para justificar la propuesta:

I. no establece, en forma expresa, que deban impartirse directrices (guidelines) para las segundas comunicaciones nacionales de los países no Anexo I;

II. tampoco prevé la necesidad de establecer restricciones en la asistencia que, de acuerdo con las normas vigentes, el GEF debe proveer a los países no Anexo I, hayan o no presentado su comunicación inicial;

III. en el literal d) del numeral 1 (Decide) de la citada Decisión, se estableció lo contrario a lo propuesto: "Sufragar la totalidad de los gastos convenidos de las comunicaciones iniciales y siguientes, de conformidad con el párrafo 3 del articulo 4 y el párrafo 5 del artículo 12 de la Convención y con el apartado d) del párrafo 1 de la decisión 11/CP.2, manteniendo y fomentando la capacidad nacional correspondiente, a fin de preparar las comunicaciones nacionales iniciales y segundas teniendo en cuenta la experiencia, comprendido las insuficiencias y problemas constatados en las anteriores comunicaciones iniciales y las directrices establecidas por Conferencia de las Partes";

d) asimismo, mediante los literales a), b), c), e), f) y g) del numeral 1 (Decide), de la decisión 2/CP.4, se reafirmaron e identificaron diversos puntos para los cuales el GEF debe facilitar recursos financieros, acorde con lo previsto por los numerales 3. y 5. del art. 4 de la Convención. Los mismos van más allá de la elaboración de comunicaciones nacionales: medidas de adaptación, necesidades de tecnologías, participación en redes de observación sistemática, programas nacionales, sensibilización y educación del público, creación de capacidades, etc.;

e) no se cree oportuno ni conveniente establecer algún tipo de restricciones en la asistencia que debe proveer el GEF a países no Anexo I y menos aún, a aquellos que han cumplido con el compromiso previsto por la Convención en su artículo 12;

f) la medida propuesta tendría carácter discriminatorio: aquellos países no Anexo I, que no hubieran presentado comunicaciones iniciales o que habiéndolo hecho no hubieran pasado por la evaluación técnica mencionada, mantendrían la capacidad de recibir del GEF la asistencia establecida por las normas vigentes (asistencia no restringida);

g) concluyendo, se entiende que la propuesta no está debidamente sustentada, que por sus características y limitaciones no es justa, ni conveniente ni oportuna y tiende a generar un retroceso en el proceso de negociación.

2. Comentario general respecto al apoyo técnico y financiero del GEF

Parecería razonable que, sin perjuicio de los esfuerzos puntuales (comunicaciones nacionales, inventarios, etc.), la asistencia del GEF para el fortalecimiento institucional de los países no Anexo I, se enfocara en ayudar a la definición y establecimiento de políticas y medidas generales para la mitigación, programas de abatimiento voluntario de emisiones, actividades de proyectos de mecanismo para el desarrollo limpio, planes de acción y de otras actividades conexas (sociales, económicas, tecnológicas y culturales), con la finalidad de lograr, en el largo plazo, un sostenido decrecimiento en la intensidad de emisión de carbono en las economías de esos países.

A. COMMENTS ON A COP 5 DRAFT DECISION ON THE CONSIDERATION

OF NATIONAL COMMUNICATIONS OF NON-ANNEX I PARTIES

Proposals submitted both by Great Britain on behalf of the European Community and also by the Group of 77 and China contain major and principal elements of the forthcoming COP decision on the consideration of national communications of the non-Annex I Parties. The work of the informal consultative groups in the period up to the Eleventh Session SBI and selection of constructive base for this issue in our opinion can promote implementation of the Convention and achievement of its ultimate objections. Supporting the basic ideas of the approach to the structure and main clauses of the Draft Decision and looking forward to the achievement of consensus on it, we provide our comments on some items of the Draft Decision.

Focussing on the necessity of implementation of Articles 4.1, 4.3, 4.4, 4.5, 4.7, 4.8 and 4.10 of the convention in Preamble to the Decision is thought to be important. Providing with financial and technical support by Parties included in Annex I and meeting their commitments on dissemination and transfer of environment-friendly technologies on non-commercial basis will significantly facilitate the implementation of the Convention at the national level. The mention of the NCSP activity and high estimate of its actuality in Preamble to the Decision is considered to be necessary.

Allowing for variety of problems of the Convention implementation at the national level, their regional peculiarity and potential actuality of activity, Uzbekistan considers it to be expedient to support the creation of non-Annex I Group of Experts for the period by the completion of preparing the initial national communications. Including the Uzbekistan representatives into these thematic groups is regarded to be necessary. Review of activity of Thematic Group of Experts might be a base for opportune revelation of the Convention implementation problems by non-Annex I Parties and for development of constructive ways to cope with these problems.

It is thought to be important to include the paragraph on the degree and terms of financial support of non-Annex I Parties in the post-communication period during preparation of second national communication into the Draft Decision.

Uzbekistan supports attaching the priority to works on preparation of regional databases on emission factors and technologies. A cycle of studies of local emission factors should be undertaken. Introduction of them into the national greenhouse gas inventories instead of averaged IPCC coefficients will considerably increase the accuracy of national data on emissions, and it is especially important in the post-Kyoto period. In our opinion, the preparation of technical paper in these issues will be required. Therefore, we facilitate the inclusion of the item on GEF financing the activity of developing countries which have submitted their initial national communications and passed the procedure of technical assessment particularly related to more precise definition and correction of national emission inventories, exploration of local emission factors, vulnerability assessment and adaptation options. Supporting the proposal on annual renovation of national greenhouse gas inventory Uzbekistan notes that this work can require financial support and should be included into the GEF programmes.

The Republic of Uzbekistan considers the setting of a three-year period of submission of second and subsequent communications from the date of the initial communication for most non-Annex I Parties except the least developed countries to be possible.

B. COMMENTS ON THE FINANCIAL ASPECTS OF DECIDING COP-5 CONSIDERATION OF NATIONAL COMMUNICATION FROM

Future decisions at COP-5 on consideration of national communication from non-Annex I Parties in the aspect of financial and technical support must contain a section on conditions and nature of granting the financial resources for post national activities. As far as a decision on guidelines of preparing the second national communication and corresponding guidance GEF will be accepted not earlier COP-6, but technical evaluation of first national communication in view of their increase amounts can require a significant time, on-our opinion, there are gaps on their financial support of that not many Parties' activity, already present their own first national communications. In particular, as far as each in the process of preparing the initial national communication, necessary when compiling to select priority directions and discuss them on COP-5 and COP-6 for the separation of necessary funds for these directions.

Considering various problems on the implementation of the Convention on the national level often their regional peculiarity, consider that working the informal consulting groups at a period before 11 sessions SBI, as well as an account of opinions of the Parties and additional needs for the light on post Kyoto activity are to assist on eliminating the gaps and revising decisions on financial and technical support to non-Annex I Parties.

1. In order to make these submissions available on electronic systems, including the World Wide Web, these contributions have been electronically imported, scanned and/or retyped. The secretariat has made every effort to ensure the correct reproduction of the texts as submitted.

FCCC/SBI/1999/MISC.4

GE.99-