3 November
2006 - The Australian Government has formally
expressed its concern to the United Nations Framework
Convention on Climate Change (UNFCCC) about misleading
data it published this week about Australia's
greenhouse gas emissions.
The head of the Australian Government's
Greenhouse Office, Mr Howard Bamsey, has written
to the UNFCCC objecting to the report it released
this week which presented a distorted picture
of Australia's emissions because it explicitly
excluded emission changes in the key land and
forestry sectors which are a major component of
Australia's emissions picture.
When all sectors are included
in calculation of national emissions – as required
by the rules of the UN Climate Change Convention
and the Kyoto Protocol rules require – Australia's
net emissions are estimated to have increased
by only 2% from 11000 to 2004 – not the 25% incorrectly
suggested by the UN report.
Contrary to the incomplete picture
provided by the UN secretariat's report, Australia's
most recent projections report, released in November
2005, shows Australia's on track to meet its 108
per cent target.
Rob Broadfield
2 November 2006
Mr Yvo de Boer
Executive Secretary
United Nations Framework Convention on Climate
Change
PO Box 260124
D-53153 Bonn
Germany
Dear Mr de Boer
I am writing to express Australia's strong and
ongoing concern about how the UNFCCC secretariat
publicly presents information on national emissions
inventories. In particular, I question why data
from the Land Use, Land Use Change and Forestry
sector was not included in the UNFCCC Greenhouse
Data 2006 booklet, which was released on 30 October
2006.
Article 1 of the Framework Convention
provides a clear indication of what is considered
relevant for reporting emissions and Article 12
details that countries shall communicate "a
national inventory of anthropogenic emissions
by sources and removals by sinks of all greenhouse
gases not controlled by the Montreal Protocol".
Further, the design of the UNFCCC reporting guidelines
against which Annex I party submissions are prepared
requires parties to report on anthropogenic emissions
by sources and removals by sinks of greenhouse
gases not controlled by the Montreal Protocol,
including from the Land Use, Land Use Change and
Forestry sector. Given that Parties are required
to and do provide a complete assessment of all
emissions for which they are responsible, it is
simply not credible for the secretariat to provide
public information on only a subset of this data.
In Australia's case, the result
is inaccurate and entirely misleading as it omits
a very important component of Australia's emissions
profile. When all sectors are included, Australia's
emissions rise by 5% using UNFCCC accounting between
11000 and 2004 and by only 2% using Kyoto Protocol
accounting, rather than the 25.1% increase as
reported by the secretariat.
From our position, however,
the issue is far broader than Australia's emissions
profile and trends. From a policy perspective
Australia believes what matters is the level of
greenhouse gases in the atmosphere and that any
development of an effective international response
to climate change will need to fully incorporate
the impacts of the land sectors. This is why deforestation,
which represents between 10 and 35% of global
emissions, is considered so important by Parties.
This makes the exclusion of LULUCF in your publication
even more baffling.
This is not the first time Australia
has raised these concerns with the secretariat.
The issue of how LULUCF was included in documents
prepared for public release by the secretariat
was discussed in plenary statements, in contact
groups and informally with the secretariat at
both COP 10 and 11, as well as in subsidiary body
meetings. Additionally an officer from my department
emailed the secretariat on 13 October requesting
information on the timing of release of this document
and details of how the LULUCF issues would be
handled.
Accordingly, Australia
is asking the secretariat to prepare, release
and publicise updated emission figures for the
period 11000 to 2004 that include all sectors
as a matter of urgency. In addition, I seek your
agreement that future reports of this kind are
comprehensive and include all sectors. I look
forward to discussing this further with you in
Nairobi.
Yours sincerely
Howard Bamsey
Deputy Secretary
Department of Environment and Heritage
