Preliminary Responses Submitted by the Government of Japan

on Issues of Document FCCC/SBSTA/1999/5 about Sinks

The Government of Japan (GOJ) submitted to the SBSTA information related to Article 3.3 of the Kyoto Protocol (KP) on August 26, 1998, and information related to Article 3.4 on October 26, 1999. In addition, the GOJ submitted information about policy and procedural issues associated with Article 3.3 and 3.4 on March 12, 1999. It is of prime importance that these submissions be fully taken into account and be properly addressed at SBSTA and IPCC discussions.

For the purpose of dealing with the issue of Land Use, Land Use Change and Forestry (LULUCF), the GOJ believes that it is important to take a definitive step forward to reach an international agreement about sink issues that is fair and contributes to the prevention of global warming. It should be achieved by further collaboration between the SBSTA and the IPCC with regard to further elaborating the issues by recognising the importance of each role.

Hereinafter, the GOJ is taking this opportunity to deliver its view on issues concerning tables 1 and 2 of document FCCC/SBSTA/1999/5, based on the conclusions from the SBSTA 10^th session which stated that, “ invited Parties are requested to 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 or procedural questions. It requests Parties to provide submissions… on those issues by 16 August 1999, for compilation into a miscellaneous document, and for consideration by the SBSTA at its eleventh session.” Yet, the GOJ notes that additional policy and procedural issues should be clearer after the completion of the IPCC Special Report on LULUCF.

Comment on Table 1. Policy and procedural issues proposed for consideration before the sixth session of the Conference of the Parties (COP6)

A.Clarification of definitions

(3)Which, if any, policies and programmes resulting in human-induced activities should be included under Article 3.3 and 3.4?

　Policies and programs should be evaluated based on those effects that are related to Articles 3.3 and 3.4 and which stem from human-induced activities resulting from said policies and programs.

B.Eligibility of additional activities 　

　It is important that the additional activities be determined at COP6. However, data and information collection of additional activities is generally regarded to be activity-specific and complicated compared to Article 3.3 activities. Therefore, the framework should be flexible enough, especially in the context of time, to judge the eligibility of additional activities. In other words, it is necessary to consider a framework which provides for continuous review and reconsideration of the eligibility of additional activities even after COP6 by COP/MOP1 to allow for new scientific and technical methodologies and means to be included in the framework.
　

(3) Should levels of uncertainty be a criterion for the inclusion of additional activities under Article 3.4? And if so, should these levels of uncertainty be different from those associated with Article 3.3 or other sources?

　Levels of uncertainty should be an important component of criteria for the inclusion of additional activities under Article 3.4. Yet, to avoid excluding eligible activities due to uncertainties, it is also necessary to consider other reasonable means such as capping and discounting for reducing uncertainties in order to be able to deal with these activities under Article 3.4. Furthermore, in addition to levels of uncertainty, levels of reporting transparency and verifiability should be also included as a criterion of Article 3.4. And it is necessary to set the framework for including new activities when an appropriate measure to reduce the uncertainties is taken and which works sufficiently after taking the decision on the levels of uncertainty at COP6.

(4) What specific information on uncertainties and verifiability is required to determine whether an additional activity should be included under Article 3.4?

In order to increase verifiability, at least the following elements should be contained:

- data, sources and methods can be reviewed; and

- repeated accounting is possible.

(5) What other criteria should be applied to guide a decision-making process in relation to Article 3.3 and 3.4?

As stated in Article 2, the following criteria should also be taken into account in the process of decision making of Article 3.3 and 3.4:

- whether the activity protects and intensifies sinks and sources for greenhouse gasses,

- whether the activity promotes sustainable forest management, afforestation and reforestation. 　

　Furthermore, the GOJ requests that a criterion of, “consistency of carbon balance” should be also applied to Article 3.4. With regard to defining activities falling under Article 3.4, in order to prevent an imbalance from arising in the carbon balance, it is necessary to treat multiple activities as components of a single set, establishing the definition in such a way that emissions-controlling activities and emission-promoting counterpart activities are symmetric, as is the case with ARD activities under Article 3.3.