Submission on
Land-Use, Land-Use Change, and Forestry
The Government of Japan

August 1, 2000

Textual Proposal of the Government of Japan regarding Article 3.3 and 3.4

I. Basic position concerning the Land-Use, Land-Use Change, and Forestry activities under the Kyoto Protocol

1.  Land-Use, Land-Use Change, and Forestry activities play an important role in GHG emissions and removals. They should be treated in as comprehensive a way as possible within the framework of the Kyoto Protocol to provide appropriate incentives for emissions reductions and enhancement of removals with continuous efforts to reduce uncertainties.

2. The Kyoto Protocol specifies that accounting under Article 3.3 be limited to ARD since 1990. The Government of Japan, therefore, believes an approach which addresses activities in a comprehensive manner to be taken under Article 3.3 and 3.4 is necessary for the reasons outlined in 1 above.

3. Further, it is necessary to define activities and design an accounting framework which make it possible to provide appropriate incentives in accordance with distinctive circumstances unique to each country. In the case of Japan, ongoing efforts to manage forests have resulted in two-thirds of the country's total land area being covered by forests. As population density is quite high and industrial activities are quite common all around the country, the land available for afforestation or reforestation is strictly limited. Thus, for a country like Japan, activities which contribute to carbon sequestration through appropriate management of existing forests are of the utmost importance and should be given full consideration when determining the accounting framework under Articles 3.3 and 3.4.

4. In establishing definitions and designing an appropriate accounting framework under Articles 3.3 and 3.4, the following points must be considered:
　　1) Making it possible to monitor the change of amount of carbon sequestered adequately and cost-effectively including via the use of existing statistics while reducing the degree of uncertainty as much as possible
　　2) Contributing to sustainable forest management

II. Proposal for definition and accounting framework of afforestation, reforestation and deforestation under Article 3.3

[Proposal]
Japan proposes that Parties adopt an FAO definition and an activity-based accounting framework for ARD activities.
This involves identifying the land where ARD has been occurring since 1990, and counting changes in carbon stocks during the period 2008 - 2012 as removals when the amount of carbon stock increases and as emissions when it decreases. Changes in carbon stock in soil and residual organic matter, however, are not counted.
In addition, for activities under Article 3.3, emissions and removals of GHGs other than CO2 may be counted in case of activities such as forest nitrogen fertilization or planting on wetland.

[Explanation]
1.  In selecting a definition and an accounting framework under Article 3.3, proper consideration should be given to the provision of incentives which are appropriate to the state of forestry activities in countries where forest management is highly important. Specifically, the harvesting-regeneration cycle is important among the forestry activities of above-mentioned countries, and thus a definition and accounting framework that contribute to increases in carbon sequestration considering this cycle should be adopted. Present circumstances show that various options of land use compete with each other in determining how a given piece of land is used, and economically advantageous options receive priority. It is true that many of the world's forests are used in forestry as an economic activity. Therefore, it is important that the lands currently used in forestry are not subject to changes in usage, or being deforested, and that this forestland be maintained as such and continue its role as carbon sequestration. Incentives in the area of accounting will be necessary should these lands be included as lands governed under Article 3.3.

2. From this point of view, among the various existing definitions, the FAO definition can provide incentives for increasing the amount of carbon removed should the appropriate accounting framework be selected, since it covers the harvesting-regeneration cycle.　 On the other hand, the IPCC definition provides no incentives for the harvesting-regeneration cycle, in that it covers only ARD accomplished via changes in land use and excludes the harvesting-regeneration cycle entirely.

3. Among the three accounting frameworks of FAO, activity-based accounting provides strong incentives for afforestation based on appropriate forestry management activities, as it accounts for increases of carbon stock by reforestation following harvesting. Through the management of man-made forests, the starting of new accumulations of carbon by harvesting in due course as well as the immediate reforestation of harvested land will increase the removal of carbon from the atmosphere and lead to sustainable forest management. In Japan we have man-made forests of ten million hectares which comprise 40% of all forest area. Such a figure is significant and to strengthen these forests as sinks and reservoirs of GHGs through appropriate forest management contributes positively to preventing global warming and, especially in Japan, environmental conservation and promotion of forestry.

4. Activity-based accounting incorporates only increases of amount of carbon sequestered in soil resulting from the growth of plant afforested. Since excluding soil carbon will underestimates credit accrued, it will be acceptable for not including soil carbon in the accounting.

5. On the other hand, land-based I accounting is inappropriate to promote sustainable forest management on the basis of the harvesting-regeneration cycle, as it works as a disincentive for harvest in normal forestry activities, because net debit will be accrued from accounting carbon stock loss on forest land resulting from harvest.

6. In land-based II accounting, changes in carbon stock in soil and residual organic matter play an important role in accounting, yet accurate measurement and estimation of these changes for all land under Article 3.3 is extremely difficult at present. In addition, this accounting framework currently brings exorbitant costs involved in attempting to estimate such changes to an appropriate degree of accuracy. Therefore, from the perspective of cost-effectiveness, land-based II accounting seems not to be practical accounting framework.

7. For the accounting of GHGs other than CO2, only accounting in special cases, such as those GHGs released from nitrogen fertilization and from planting on wetland, should be considered, though emissions of these gases in forest activities are negligible in Japan.

III.How and which additional activities are to be included in Article 3.4 (including structures, rules, guidelines and accounting framework related to these activities)

[Proposal]
Japan holds the view that forest management and urban greening etc. should be included in activities under Article 3.4, and supports the broad definition and activity-based accounting for activities under Article 3.4.
With regard to the broad definition, the Government of Japan suggests that each country should identify practices constituting each activity in accordance with the situation unique to each country, and then identify land where these practices are carried out. For identified land, net removals of CO2 should be accounted for by estimating changes in the amount of removals by subtracting the carbon stock reference figures for 2008 from those for 2012.
Changes in the amount of carbon in soils and residual organic matter should not figure into the accounting.
For forest management, emissions and removals of GHGs other than CO2 should be included in the accounting, although they will only be adopted to the special cases such as nitrogen fertilization and planting on wetland.

[Explanation]
1. It is not appropriate to enumerate all the practices fitting within the narrow definition and then decide whether or not they should be classified as activities falling under Article 3.4, because the practices of forest and farmland management differ by country. Adoption of a broad definition is thus more practical.

2. In adopting the broad definition, it is practical to identify practices constituting the activities of forest management and so on in accordance with the circumstances existing in each country first. And then to identify the lands on which these practices are carried out as the lands for activities under Article 3.4.

3. It is appropriate to adopt activity-based accounting for Article 3.4 in order to have consistency with accounting framework under Article 3.3. Under the broad definition, different practices would be accounted as one incorporated activity; hence, the problem of double accounting when multiple practices on one section of land exist would not arise.

4. In accounting, a counterfactual baseline in order to separate natural changes and human-induced changes may increase uncertainty, and indeed, the setting of the baseline may have to be decided arbitrarily. While there is another way of setting up control areas not subject to human-induced activities, in terms of cost and its effectiveness, it is impractical to set up these control areas taking into account various factors such as species planted, landform, climate and so on. Also, in certain cases, it might take a long time until results become evident. For these reasons, estimating the change of carbon stock by subtracting the carbon stock reference figures for 2008 from those for 2012 seems to be the most practical way.

5. Changes in the amount of carbon in soils and residual organic matter should not figure into the accounting because it is extremely difficult to conduct highly accurate estimations of these changes cost-effectively.

6. For the accounting of GHGs other than CO2, only accounting in special cases, such as those GHGs released from nitrogen fertilization and from planting on wetland, should be considered, though emissions of these gases in forest activities are negligible in Japan.

IV. Measuring and reporting methodologies under Articles 3.3 and 3.4 of the Kyoto Protocol

[Proposal]
1. Parties should account for emissions and removals of CO2 by measuring or estimating changes of carbon stock for both Articles 3.3 and 3.4.

2. Relating to changes of carbon stocks, Parties should measure or estimate changes of carbon stock between 2008 and 2012.

3. Each country should determine its most appropriate method of measuring and estimation in accordance with its own unique situation in to the view point of reducing uncertainty and enhancing verification, taking into account both the relationship between the accuracy of measurement and estimation and the costs involved. There would be several methods including one using basic units, one incorporating both remotely-sensed data and surface data, one using models and direct measurement, and so on.

4. In conducting practical accounting, it is essential to make good use of existing statistics to carry out national level accounting cost-effectively.

5. When reporting, in order to ensure transparency, it is necessary to clarify measuring and estimation methods used so as to make possible verification by third parties.

V. Overall accounting approaches corresponding to requirements of Article 3.3, 3.4 and 3.7 of the Kyoto Protocol (especially correlation between reversibility, natural effects and accounting inter-linkages)

[Proposal]
1. In accounting, commitment periods should set contiguously and account for both emissions and removals. By doing this, even for reversible activities, accurate calculation of emissions and removals at each time when the activities are conducted, will make it possible to demonstrate the exchange of GHGs between sources/sinks and the atmosphere precisely.

2. It is necessary to establish a counterfactual baseline in order to separate natural changes from human-induced changes, which may increase uncertainty, and the setting of baseline may have to be decided arbitrarily. There is another way of setting up control areas not subject to human-induced activities, but in terms of expense and effect it is impractical to set up these areas taking into account species, landform, climate and so on. Also, in certain cases, it might take a long time until effects become evident. Therefore, in terms of reducing uncertainty and excluding arbitrary estimation, accounting should be done by subtracting the carbon stock reference figures for 2008 from those for 2012, without separating out natural effects.

3. Activities under Articles 3.3 and 3.4 should be estimated in the same accounting framework to ensure consistency in accounting between Article 3.3 and 3.4.

4. It is appropriate to treat GHG emissions from agricultural soil under Article 3.1 on the basis of provisions under the Kyoto Protocol. Activities, however, that lead to increase amount of removals of GHGs should be treated under Article 3.4.