24 September 1999

ENGLISH ONLY

UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE

SUBSIDIARY BODY FOR SCIENTIFIC AND TECHNOLOGICAL ADVICE

Eleventh session

Bonn, 25 October - 5 November 1999

Item 9 (a) of the provisional agenda

1. In addition to the submissions included in document FCCC/SBSTA/1999/MISC.7, a submission from Finland, on behalf of the European Community and its member States, was received on 17 September 1999.

2. In accordance with the procedures for miscellaneous documents, this submission⁽¹⁾ is attached and reproduced in the language in which it was received and without formal editing.

Finland, on behalf of the European Community and its Member States, emphasises the need for country specific data and information and their relationship to a decision-making framework in the context of the requirements of the Kyoto Protocol. The EU submits views in accordance with FCCC/SBSTA/1999/L.9, paragraph 1(f) regarding methodological issues on Land-Use, Land-Use Change and Forestry.

The EU recalls its earlier submissions, in particular, as presented in the documents FCCC/CP/1998/MISC.1, FCCC/CP/1998/MISC.9 and FCCC/SBSTA/1999/MISC.2, as well as its submission on "Review, and where possible to respond to, the questions posed in tables 1 and 2 of document FCCC/SBSTA/1999/5, and to identify any additional policy and procedural questions".

The EU submits views on:

(i) The need for and the usefulness of country specific data and information,

(ii) Meeting the requirements related to the first sentence of Article 3.4,

(iii) Requirements for country specific data and other information in regard to the activities under Article 3.3,

(iv) Requirements for country specific data and other information in regard to possible additional activities under Article 3.4,

(v) Country specific data and information in relation to Article 3.7,

(vi) Other issues related to country specific data and other information and

(vii) The decision-making process in relation to the above-mentioned issues.

The primary need is to obtain country specific data and information from Annex B countries since removals by sinks under the present Kyoto Protocol only concern those Parties.

1. The need for country specific data and information

The EU believes that substantial, balanced and well-informed decisions can only be made on the basis of consideration of the IPCC Special Report on Land-Use, Land-Use Change and Forestry and the availability of country specific data and other relevant information. At the second SBSTA meeting of experts in Indianapolis on 26-28 April 1999, some lead authors of the IPCC Special Report expressed their concern that the Special Report, in its present form, would not be able to provide detailed country specific data on changes in carbon stocks. Therefore, the report may also lack country specific estimates of actual and potential changes in carbon stocks due to Article 3.3 and Article 3.4 activities and the relationship between these Articles and Art. 3.7.

The EU has expressed in its earlier submissions that there are several aspects which underline the importance and usefulness of country specific data and information. Relevant issues include the following:

1) The Kyoto emission limitation and reduction targets for the first commitment period are fixed but the means for achieving targets using the sink allowance are not yet determined. The EU believes that the incentive for emission reductions should be maintained and without country specific data it will be difficult or impossible to determine what the implications for emissions reductions of including additional sink activities will be for individual Parties.

2) Without country level data and information provided by countries themselves, balanced and credible decision-making on definitions to operationalise Art 3.3, on modalities rules and guidelines for Art. 3.4, and the relationship between these Articles and the second sentence of Art. 3.7 will be difficult or impossible.

3) It is important to guarantee that the sink enhancement resulting from an activity will not lead to depletion of other carbon pools. Similarly, stock changes resulting from Article 3.4 as well as from Article 3.3 activities should adequately reflect the direction of changes of all carbon stocks. The assessment of changes in carbon stocks can only be done by using country specific data and information.

4) The relationship between Art. 3.3, Art. 3.4, and the final sentence of Art. 3.7 should be such as to avoid double accounting and other unintended effects. Parties need to provide country specific data showing how proposed sets of activities will work together in a sustainable manner.

5) It is important to guarantee transparency in the further work and negotiations on sink accounting. Uncertainties associated with the data need to be minimised by addressing it at a sufficiently detailed level. Country specific data and information will help to address these concerns.

6) The inclusion of sinks in the Kyoto Protocol as well as the subsequent work has demonstrated a need for an ongoing scientific, technical and political learning process that can be facilitated by country specific data and information. Given the context of making decisions on these matters, as reflected in the second sentence of Art. 3.4, exchange of practical experiences on methodological and data questions, reporting and verifiability issues, uncertainties as well as country-level analysis of the estimated implications of the Kyoto Protocol is of crucial importance. Furthermore this exchange can also support the further development of the IPCC guidelines. The EU believes that Annex B Parties should be encouraged to use the existing systems when applicable or to develop a system for national inventories and reporting, and not rely on the use of common default factors.

7) The operationalisation of principles to be used in national inventories and reporting, such as consistency, comparability, verifiability, completeness and accuracy require that Parties provide country specific data and information prior to any decision.

8) Country specific data prior to the commitment period are also important in assessing demonstrable progress made by Parties.

2. Meeting the requirements of the first sentence of Article 3.4

The EU recalls the first sentence of Article 3.4 "Prior to the first session of the Conference of Parties serving as the meeting of the Parties to this Protocol, each Party included in Annex I shall provide, for consideration by the Subsidiary Body for Scientific and Technological Advice, data to establish its level of carbon stocks in 1990 and to enable an estimate to be made of its changes in carbon stocks in subsequent years." The EU also recalls paragraph 6 of decision 9/CP.4 which "Requests the SBSTA to consider, at its tenth session, the requirements necessary to fulfil the provisions of the first sentence of Article 3.4 of the Kyoto Protocol, ...". The EU notes that SBSTA at its tenth session did not in fact provide adequate opportunities to deal with the issues.

The EU further recalls its earlier submission, presented in the document FCCC/SBSTA/1999/MISC.2. Country specific data on carbon stocks and other relevant information can be presented in a segregated manner for (i) forest and other wooded lands biomass (ii) forest and other wooded lands soil carbon stock, (iii) agricultural soils and (iv) other soils. The purpose of these data is to identify, at the national level, the extent of different carbon stocks and their changes in subsequent years and to help to ensure that the specific activities included under provisions of Articles 3.3, 3.4 as well as the second sentence of Art 3.7 do not lead to unintended effects given the provisions under the UNFCCC to protect and enhance sinks and reservoirs in general.

These data should be provided for the year 1990 and subsequent years and estimates provided for the years 2000, 2005 as well as for the first commitment period 2008-2012. The EU recognises that countries do not undertake complete carbon inventories every year and that annual data are based on stock change estimates. Parties, including Annex B Parties for whom the second sentence of Art. 3.7 applies, are encouraged to provide the country specific data also prior the year 1990. In order to facilitate the discussion, the EU presents a provisional draft format which Parties could use in their submission on data and other information as described in Appendix 1. In view of the need for transparency and comparability, the reporting of such data should be accompanied by a description of the methodologies used in deriving the data, and estimates of the uncertainties of the data.

Parties should provide these preliminary data and information by 15 April 2000.

3. Requirements for country specific data and other information with regard to the activities under Article 3.3

The EU notes that country specific data and other information to enable the assessment of implications of different definitions of afforestation, reforestation and deforestation, for instance those from the IPCC and ECE/FAO and other definitions countries consider relevant, should be provided by Parties prior to the decisions on these definitions. The experiences obtained by the country presentations held in the SBSTA Workshops in Rome and Indianapolis are relevant when considering the format for providing this data and information. In addition to data on carbon stock changes and land areas linked to Art. 3.3 activities during the first budget period, information may include estimates on the implications on the assigned amount and on whether the direction of changes in total carbon stocks is adequately reflected. Information on, inter alia, uncertainty of data is also relevant. The EU believes that Parties should agree on the format at SBSTA 11. To facilitate the discussion, the EU intends to provide a provisional draft format for reporting these country specific data at SBSTA 11. It is important that sufficient time will be allocated for consideration of these issues at SBSTA 11. Countries should provide the country specific data and information by 1 August 2000 for discussions in the forthcoming SBSTA Workshop after the consideration of the IPCC Special Report.

4. Requirements for country specific data and other information with regard to possible additional activities under Article 3.4

The EU is not opposed to the idea of adding new activities under the provisions of Article 3.4 per se, but one of the EU's main concerns is about implications during the first budget period for which reduction targets already have been set given the need to maintain incentives to reduce gross emissions and keeping in mind the ultimate objective of the Convention. While noting, that the term "activity" will require further consideration, the EU views that estimates of the implications of possible additional activities should be reported in a transparent way which enables, inter alia, the assessment of the potential magnitude of related carbon stock changes and which provides relevant methodological information. It may be necessary to consider a more comprehensive approach on changes in carbon stocks towards the second and consecutive commitment periods but only credit a certain proportion of sink under Article 3.4 during the first commitment period.

The EU believes that Parties should agree on the format for providing these country specific data and information at SBSTA 11. To facilitate the discussion, the EU intends to provide a provisional draft format for reporting these country specific data at SBSTA 11. It is important that sufficient time will be allocated for consideration of these issues at SBSTA 11. Countries should provide the country specific data and information by 1 August 2000 for it to be discussed in the forthcoming SBSTA Workshop after the consideration of the IPCC Special Report.

5. Meeting the requirements of the second sentence of Article 3.7

The EU believes that this sentence requires detailed consideration for balanced and well-informed decisions related to land-use, land-use change and forestry. Country specific data and information will enable, inter alia, to quantify impact of this sentence in the light of long- term trends in the changes in carbon stocks, and to explain the relationship between the Art. 3.7 and proposed definitions for activities under Articles 3.3 and 3.4.

Annex B countries for which provisions of this sentence apply, should provide data and information on meeting the requirements of this sentence. Country specific data and information would include the data and information requirements mentioned above to fulfil the first sentence of Article 3.4, noting the relevance of data prior the year 1990, and explanation of the relationship of Art. 3.7 with Articles 3.3 and 3.4. Furthermore, these countries should explain how they differentiate "land use change" and "land-use change and forestry".

These data and information should be provided by 15 April 2000.

6. Other issues related to country specific data and other information

As the EU has indicated in its earlier submission, the term "activity" requires further consideration. Depending on how broadly or narrowly activities are defined, issues such as availability of data and overlapping activities may need special attention.

Monitoring of changes in carbon stocks may require different approaches compared to monitoring of emissions from other sectors due to the unique nature of sinks and also due to the methodological practices used for the measurement of removals by sinks. Some considerations in this regard include:

- Because of annual variation of temperature and precipitation as well as biotic processes, there may be a great annual variation in the increment of growing stock of forest and other vegetation and thereby in removals by sinks.

- There may be a great annual variation of total harvesting and drain of trees as well as of the clearance of other vegetation.

- Changes in the carbon stock of the aboveground biomass are usually observed and measured with a periodicity of 5-10 years, whereas the belowground and soil carbon stock changes may need an even longer period of time to be measured with acceptable levels of precision.

- At the moment, very few countries, if any, are able to report measured annual increment. This is because the increment figures provided by Parties are derived from inventory calculations based on periodic measurements. However, changes in carbon stock through harvesting and also areas of planting and/or regeneration can be measured on an annual basis. Complexity and costs of data collection and reporting are also relevant in this context.

7. Country specific data and information and the decision-making framework

The EU believes that the decision-making framework and the provision of country specific data and information could include the following steps up to the SBSTA-13/(COP-6):

Timeframe	Data on requirements according to the first sentence of Art. 3.4	Country specific data and information on Art. 3.3 activities	Country specific data and information on additional Art. 3.4 activities	Data on requirements according to the second sentence of Art. 3.7	Decision-making process in light of country specific data and information
Inter-sessional period before SBSTA-11					* Submission on policy and procedural issues. * Submission on country specific data and information and their relationship to decision-making framework.
SBSTA-11					* Consideration of the process and timing for the analysis of the information including that provided by the IPCC Special report. * Consideration of policy and procedural issues and the decision-making process. * Consideration of the need for country specific data and information in the context of the Kyoto Protocol requirements * Consideration of formats for provision of country specific data and information on requirements according to the first sentence of Art. 3.4, Art. 3.3 activities and possible additional activities under Art. 3.4
Inter-sessional period	Provision of preliminary country specific data and information by 15 April 2000			Provision of country specific data and information by 15 April 2000.	* Submission on the scope of the Workshop, including information and a decision-making framework by 1 February 2000.
SBSTA-12	Consideration of these country specific data and information - in parallel with the IPCC Special Report			Consideration of these country specific data and information - in parallel with the IPCC Special Report	* Consideration of the IPCC Special Report.
Inter-sessional period		Provision of country specific data and information by 1 August 2000	Provision of country specific data and information by 1 August 2000
Workshop	Further analysis of country specific data and information.	Analysis of country specific data and information.	Analysis of country specific data and information	Further analysis of country specific data and information.	Analysis of the IPCC Special Report in the context of country specific data and information.
Inter-sessional period					* Submission on possible outstanding issues related to Art. 3.3 *Submission on modalities, rules and guidelines for additional human-induced activities under Art 3.4.
SBSTA-13 (COP-6)					* A draft decision on definitions related to activities under Art. 3.3 * A draft decision on modalities, rules and guidelines on additional human-induced activities under Art. 3.4. * A draft decision on guidelines for supplementary information under the provisions of Art. 7.1 and 7.4 (or as soon practicable thereafter)

After the draft decisions are made at the Thirteenth Session of the SBSTA-13 (and the Sixth Session of COP), the EU believes that there will still be a need for continued work, inter alia, on (i) the IPCC to prepare inventory guidelines for the implementation of Articles 3.3, 3.4 and 3.7, (ii) Parties to report in accordance with the new guidelines, (iii) a COP/MOP decision related to Articles 3.3, 3.4 and 3.7, and (iv) other methodological work under the FCCC reporting guidelines for national inventories. 17 September 1999

A DRAFT FORMAT TO PROVIDE PRELIMINARY COUNTRY-SPECIFIC DATA AND INFORMATION REQUIRED

A; FOREST AND OTHER WOODED LANDS; CARBON STOCKS OF BIOMASS, YEAR ____

Forest cover/ type	Area (1000ha)	Standing volume of trees (above ground, 1000 overbark m3) (2)	Above-ground woody biomass (tn)	Below ground woody biomass (tn)	Total biomass of forest and other wooded lands (tons of carbon)	Change in the carbon stock since 1990(3)	Estimation methods (4)	Remarks (5)
Forest land (1)
Other wooded lands (6)
Other (6)

(1) Separate lines should be completed e.g. for (i) coniferous, (ii) deciduous, (iii) mixed coniferous-deciduous,

(iv) tropical, (v) etc. as appropriate. Data based on national classifications and their relationship to

internationally agreed classifications may be provided as a footnote or in a separate sheet.

(2) Include growing stock (stemwood and/or whole tree) and dead trees

(3) Include (i) increment (stemwood and/or biomass), (ii) annual harvest (stemwood and/or biomass), (iii) mortality, and (iv) net change in growing stock.

Countries should provide at least preliminary estimates for data.

(4) Including conversion factors or use of IPCC default factors, source of data, frequency and coverage of inventories, uncertainties, verification and validation of data. Information should be provided as a footnote or in a separate sheet.

(5) Discuss e.g. missing values and/or lack of national data, needs for future methodological work, etc. Information should be provided as a footnote or on a separate sheet.

(6) Please use a footnote to specify type of ecosystem.

B; FOREST AND OTHER WOODED LAND; SOIL CARBON STOCK, YEAR _____

Forest cover/type	Area by soil type (1000 ha) (7)	Soil carbon stocks in litter and soil organic matter (depth of measurement should be stated) (8)	Soil carbon stocks in mineral layers (depth of measurement should be reported) (9)	Change of carbon stock since 1990 (3)	Estimation methods (4)	Remarks (5)
Forest land (1)	a) Mineral soils b) Peat soils c) Other soils
Other wooded land (6)
Other (6)

(7) Specify by soil types, e.g. by mineral soils, peat soils and other soils, as indicated.

(8) Depth of measurement should be reported. Data should include both litter and soil organic matter or there should be an indication in a footnote whether litter is included or excluded. Information on variation by hectares should be provided as a footnote.

(9) Depth of measurement should be reported. Information on variation by hectares should be provided as a footnote

C; AGRICULTURAL SOILS AND OTHER AGRICULTURAL LAND; SOIL CARBON STOCK, YEAR ____

Agricultural soil type (10)	Area (1000ha)	Soil carbon stocks to a depth of 30 cm (11)	Soil carbon stocks a depth over 30 cm (11)	Change of carbon stock since 1990 (3)	Estimation methods (4)	Remarks (5)
Mineral soils
Peat soils (e.g. histosols)
Other soils

(10) Use separate lines to enter data for different agricultural land uses, e.g. tilled land, pasture, set-aside or conservation.

(11) Use a footnote to report depth below 30 cm to which carbon is estimated, and also indicate depth of upper layer if different from 30 cm. Information on variation by hectares should be presented as a footnote or on a separate sheet.

D; OTHER SOILS; SOIL CARBON STOCK, YEAR ____

Soil type (12)	Area (1000ha)	Soil carbon stocks by organic layers. (depth of measurement should be stated) (11)	Soil carbon stocks in mineral soils (depth of measurement should be stated) (11)	Change of carbon stock since 1990 (3)	Estimation methods (4)	Remarks (5)
Mineral soils
Peat soils
Other soils

(12) Lines should be split according to national land use classifications, and/or alternative soil types be used. These should be explained in a footnote.

1. In order to make this submission available on electronic systems, including the World Wide Web, it has been electronically imported. The secretariat has made every effort to ensure the correct reproduction of the texts as submitted.

FCCC/SBSTA/1999/MISC.7/Add.1

GE.99-