中国气候变化信息网 China Climate Change Info-Net
Submission by China
on the Draft Technical Guidance on Methodologies for Adjustments
under paragraph 2, Article 5, of the Kyoto Protocol
March 12, 2003
China welcomes opportunity to send views on the Draft Technical Guidance on Methodologies for Adjustments under Article 5, paragraph 2, of the Kyoto Protocol (hereinafter referred to as the draft technical guidance) contained in document FCCC/SBSTA/2002/INF.5, in consideration of results of Case Studies for Simulating the Calculation of Adjustments under Article 5, Paragraph 2, of the Kyoto Protocol (hereinafter referred to as the case studies) contained in Working Paper No.1 of UNFCCC Secretariat, in accordance with Paragraph 24 (h) of document FCCC/SBSTA/2002/6.
1. The conditions that adjustment shall be applied
Regarding the issue of the conditions that adjustment shall be applied, China has three proposals:
1) Delete the second sentence of paragraph 4 of the Draft Technical Guidance
Paragraph 3 of Draft Decision -/CMP.1 (Article 5.2) states: "Decides that adjustments referred to in Article 5, paragraph 2, of the Kyoto Protocol shall be applied only when inventory data submitted by Parties included in Annex I are found to be incomplete and/or are prepared in a way that is not consistent with the Revised 1996 IPCC Guidelines for National Greenhouse Gas Inventories as elaborated by the IPCC good practice guidance and any good practice guidance adopted by the Conference of Parties serving as the meeting of the Parties to the Kyoto Protocol.
Differently, the second sentence of paragraph 4 of the Draft Technical Guidance says: "If the expert review team finds that an estimate is not prepared in accordance with the Intergovernment Panel on Climate Chang (IPCC) Guidelines as elaborated by the IPCC good practice guidance, but evidently does not lead to an overestimation of emissions in the base year or an underestimation in a year of the commitment period, the estimate does not have to be adjusted."
China, therefore, proposes that the second sentence of paragraph 4 of the Draft Technical Guidance mentioned above shall be deleted for two reasons. First, the relevant substantial contexts shall be maintained consistently between the Draft Decision and the Draft Technical Guidance. Second, the current statement of Paragraph 4 of the Draft Technical Guidance would possibly leave out some cases that adjustments should be applied.
For example, the case where adjustment shall be applied but would not be done so in accordance with the current statement of paragraph 4 of the Draft Technical Guidance could occur, if a Party chooses higher constant emission factors when the relevant activities data of the Party decrease. In this case, the estimation in any year of the commitment period would be underestimated as compared to the estimation of the base year, in view of the entire timing series from the base year to the years of commitment period.
2) Establish "threshold of insignificance"
China understands that adjustment would possibly be a high workload and may reduce the time available for the review team to identify inventory problems under the guidelines of Article 8, if the adjustment is applied to all identified problems, given adjustments to be time-and-resource-intensive based on experiences from the Case Studies. At the same time, China also recognizes that the sum of several mini problems-insignificant sources may go beyond an insignificant share of the total national GHG emissions of a given Party, and constitute a substantial problem for the given Party's fulfilling commitment to the Kyoto Protocol, if adjustment would not be applied to these several mini problems that occur simultaneously in one inventory submitted. To address the problem, China proposes that the "thresholds of insignificance for importance of the sources and the emission trend" should be necessarily established in the Technical Guidance. In other words, adjustment shall be applied: (1) To all mini problems if the aggregation of emissions caused by these several mini problems exceeds a certain percentage of the total national GHG emissions of a given Party; (2) To the specific source if the emission increase rate exceeds a certain percentage even though the aggregation of emissions caused by these several mini problems don't exceed the certain percentage--insignificant.
3) Establish the rules and criteria to determine a potential problem departure from the IPCC Guidelines
Experiences from the Case Studies suggest that without objective and unified rules and criteria, it is difficult for review experts to determine whether a potential inventory problem is really a departure from the IPCC Guidelines, in particular in the case where a Party estimates GHG emissions by using its own national methodologies. Accordingly the rules and criteria should be set up for determination of potential inventory problems departure from the IPCC Guidelines. And also the adjustment shall be applied, If a Party could not provide detailed description of its national methodologies.
2. Selection of adjustment methods
From the Case Studies, China noted the fact that a large number of methods applicable to each sector and different possibilities for combining them, as well as different approaches for ensuring that estimates are conservative gives expert review teams numerous options for calculating and adjustment, which thereby affects the principle of consistency in the application of adjustments. China, therefore, proposes that a decision tree for selection of methods should be established in the Technical Guidance, so as to meet its objective mandated by the draft decision -/CMP.1 (Article 5.2), which requires the technical guidance to ensure consistency and comparability and that similar methods be used for similar problems as far as possible across all inventories reviewed under Article 8. In a decision tree, the IPCC Tier1 and IPCC default values should be considered with a high priority.
3. Conservative estimates
The 25/75 rules should be applied to the factor that leads to adjustment rather than only applied to the final adjusted estimate. In this sense, Paragraph 20(a), 20(b), 20(c), and 21 of the Draft Technical Guidance needs to be changed to as:
(a) The range of emission factors available from the Annex I Parties or provided by IPCC Good Practice Guidance;
(b) The range of input parameters; in particular those provided by the IPCC Good Practice Guidance;
(c) The range of uncertainty around a point estimate from uncertainty data available provide by IPCC Good Practice Guidance;
In addition, in accordance with experiences from the Case Studies, the Draft Technical Guidance needs add the statement that the increase rate for the adjusted estimate should be higher than the original increase rate when the emission trend is increasing, or the decrease rate for the adjusted estimate should be lower than the original decrease rate when the emission trend is decreasing.
4. Improvement of the Technical Guidance
Owing to the very much complexities of adjustment methodologies and the good but limited experiences from the case studies, the Technical Guidance should be periodically revised based on experiences from the real adjustment practices.
Source: Ministry of Foreign Affairs of the People's Republic of China