In replying to the request (FCCC/SBSTA/1999/L.3 of 7 June 1999) to provide a submission to the Secretariat describing the opinion on Guidelines for national systems and methodologies for the application of adjustments, Japan submits the following comments:

Comments on Article 5.1

National systems for the estimation of anthropogenic emissions by sources and removals by sinks are important to promote compliance with emissions limitation and reduction commitments by Annex I countries, and to build a compliance regime which prevents non-compliance. Accordingly, in order to provide a basis for proper assessment of the compliance status of each country, it is important that these systems have a high level of credibility which ensures the transparency and verifiability of estimates.

For this reason, in order to adequately ensure the transparency and verifiability of estimates of emissions by sources and removals by sinks, it is important that guidelines be prepared, fully taking into account the results of discussions relating to Good Practice which are now underway in the IPCC Inventory Programme. Guidelines should have some flexibility, in order to allow existing national systems to be used effectively, to the extent that they do not damage the transparency or verifiability, because in many cases the data used in estimates are also utilized for purposes other than estimating greenhouse gas emissions by sources and removals by sinks. For example, Japan compiles much of its data on a fiscal year basis (April through March), and it would be difficult to make changes to compile all these data on a calendar year basis. Circumstances such as these should be adequately considered.

It is important to assess whether or not countries are complying with their responsibilities relating to the preparation of national systems referred to in Article 5.1. Procedures of these assessments should be discussed together with deliberations about the compliance regime for the Protocol.

Comments on Article 5.2

With regard to application of “adjustments” in Article 5.2 “where such methodologies are not used”, it is important to consider what corresponds to such cases, taking into account the results of the discussions on Good Practice, and thereon decide how to make such adjustments in such a way as to allow adequate flexibility.