CASA’s Position Paper for the third depth review of theNational Communication (Japan) to United Nations ofFramework of Convention on Climate Change
December 5, 2002
CASA (Citizens' Alliance for Saving the Atmosphere and the Earth)E-mail: casa@netplus.ne.jp

Introduction
We’d like to point out three things of the Japanese 3rd National Communication.
The first point is that CO2 emissions in 2010 are forecasted to stabilize relative to 1990
levels even “With additional measures” in “4.2.1 Future outlook for CO2 from energy
sources”. The second point is that three gases (HFCs, PFCs, SF6) emissions in 2010 are
forecasted to increase 2% relative to 1995 levels. The third point is that measures in theindustrial sector heavily depend on “the Keidanren Voluntary Action Plan on theEnvironment“.
Here, based on our studies, we’d like to talk about CO2 and three gases (HFCs,PFCs, SF6) reduction potentials in Japan and point out some problems of “the Keidanren
Voluntary Action Plan on the Environment“.

1. Possibilities for reducing CO2 emissions from energy sources
In “4.2.1 Future outlook for CO2 from energy sources”, CO2 emissions in 2010 areforecasted to stabilize relative to 1990 levels even “With additional measures” which isbased on “the Guideline of Measures to Prevent Global Warming” (2002). But thisscenario underestimates reduction potentials by technological measures because it doesn’t
count reductions from making the best of the unfamiliar existing technologies. And it
depends on constructing many nuclear power stations as well. However recent nuclear
related accidents and electric power companies’ misconducts increased the discredit ofnuclear among Japanese citizens. This would certainly leads constructing less nuclear
power stations than projected and ends up increase of CO2 emissions.
According to our CASA research (bottom-up end-user model), if you take
“Technological Measures” Option, in which 91 CO2 emission reduction technologies areintroduced, CO2 emissions in 2010 will be increased 0.1% relative to 1990 levels (Table 1).
Moreover, CO2 emissions could be greatly reduced if manufacturing, consumption,transportation, waste disposal, and other physical activity levels are kept as is or reduced(ex. canceling wasteful public works), while solar and wind power generation, etc., arepromoted. CO2 emissions in 2010 could be reduced 9.1% relative to 1990 levels with the“CASA with additional measures” Option (the "30-year nuclear phaseout case").

2. Possibilities for reducing three gases emissions“4.2.5 Future outlook for HFCs, PFCs, SF6 emissions” forecasts that three gases

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(HFCs, PFCs, SF6) emissions in 2010 could be increased 2% relative to base year (1995)
levels.
However much can now be done to cut emissions of the three gases because hardly
anything has been done to date. HFCs have many natural substitutes, which if used as
replacements will neither accelerate global warming nor deplete the ozone layer (Table 2).
As one example of the anticipated effect of reductions, CASA used released data tocalculate the effect of emission reductions in Japan in 2010, assuming that only currently
available technologies are used. It would be possible to reduce the total emissions of thethree gases about 2% lower than the 1995 level in 2010 (Table 1, Appendix 1).
Japan, the US, and other governments claim that "voluntary initiatives" aresufficient.
However, without holding governments to "voluntary initiatives" byagreements or other means, there is no guarantee of target attainment. Also, it isimpossible to exclude free riders, and governments cannot even legally require bettertargets of businesses which do not even develop plans, or which set ridiculously lowtargets. Even the Japanese government itself predicts that due to measures which areprimarily based on voluntary initiatives, 2010 emissions of the three gases will haveincreased 50% over 1995. It is clear that something else must be done.

3. Problems of “the Keidanren Voluntary Action Plan on the Environment”“3.4.2 (1) Steady implementation of voluntary action plans and follow-up” says thatmeasures in the industrial sector only depend on “the Keidanren Voluntary Action Plan on
the Environment” (voluntary plan) developed by the Japan Federation of Economic
Organizations (Keidanren). But “voluntary plan” are non-regal binding measures and wehave to say that it has fatal faults and problems such as uncertainty and opaque.
First, “the Guideline of Measures to Prevent Global Warming” forecasts CO2
emissions in the industrial sector in 2010 will be reduced 7% relative to 1990 level, while“voluntary plan” forecasts stabilization. There is no explanation why there are twodifferent reduction targets. Second, even “0% stabilization” will not be achieved because
it premises that many nuclear power stations will be built. Third, unless industrial
groups achieve the targets, no sanctions or penalties will impose on them. Enforcement
for the industry is very weak compared to the voluntary agreement in EU such as theEnergy Efficiency Benchmarking Covenant in Netherlands.
Forth, Keidanren
implemented a third-party authentication and registration system this autumn. But
most of the members consist of representations from industry and researchers closed toindustry, so it is impossible to review objectively and fairly.
For promoting measures in the industry, it is essential to set higher reduction
targets and strong sanction system against failure.

More information is available at CASA’s website.
1.

“Developed Countries Should Set Higher Reduction Targets for the Second Commitment
Period- An Exploration of the Possibilities for GHG Reductions in Japan-”
http://www.netplus.ne.jp/~casa/COP8/COP8-GHG-E.pdf

2.

“Possibilities for Reducing CFC Substitute Emissions, and Challenges for the UNFCCC”
http://www.netplus.ne.jp/~casa/COP8/COP8-THREEGASES-E.pdf
2Table 1 Effectiveness of Japan's CO2 Emission Reduction in 2010 According toCASA Scenarios
CASA scenarios
Gas type

CO2(1)Technologicalmeasures
Energyconversion sector
Industrial sector
Transport sector
Service sector
Household sector
CO2 total(2) Combinationof measures＋ 7.1％＋ 3.5％−− 9.2％−17.3％− 7.0％＋16.3％± 0.0％＋17.0％＋ 5.0％＋ 7.0％− 0.1％− 0.1％＋ 0.1％− 9.1％± 0.0％− 2.0％＋ 2.0％− 11.1％＋ 2.0％

HFC・PFC・SF6
Total for CO2, HFCs, PFCs, and SF6

Reference: New
Guideline＋ 0.1％− 2.0％(Service, household)*Note: Baseline year for CO2 is 1990; for HFCs, PFCs, and SF6 it is 1995.

Table 2 Overview of the Three Gases (HFCs, PFCs, SF6): Uses and Emissions
Main uses

Refrigerants(autoA/Cs,
homeA/Cs,refrigerators,etc.)

Insulation

SpraysManufacture
and cleaningofsemi
conductors
andliquid
crystalsInsulators

Emission characteristics•Oftenleaks
duringproduction and use, releases atdisposal time (10-15 years aftermanufacture/shipping)• Large emissions unlessrecovered at disposal time
• Most emissions 10 or more
years after manufacture• During several decades after
manufacture,graduallyreplaced by air and expelled• Emissions continue forseveraldecades
aftermanufacture•
Used,andemitted,
immediately after production•
Emittedfrom
fire
extinguishing equipment uponuse• PFCs and other substances
usedtomanufacture
semiconductors and liquid
crystals• PFCs and other substancesused to clean electronic parts,etc.
• SF6 sealed into insulators atpower
substations
andfactories using high voltage

Industries
usinggases (industriesneeding action)•Automakers,
auto part makers•Electricalappliance makers•Constructionindustry

Mainemission
times, etc.

sources,

Main substitutes•When discarding auto andhome A/Cs, refrigerators, etc.
• Huge future emission
source•Hydrocarbon
refrigerators are on themarket•CO2 refrigerant being
developed for auto A/Cs

•Chemicals,
construction
material
manufacturing,
construction• After building material
manufacture and installation• Also refrigerator insulation,etc.

• Other blowing agents
such as water andhydrocarbons• Spray industry• In Japan, most uses involve
spraying on HFCs (which areGHG) to remove dust, etc.
(not considered "essentialuses")• Few medicinal uses, which
are touted by the gases'
manufacturers• Large emission source inJapan• Many Japanese factories
are problems because theyuse gases in open systems, or
have no recovery equipment
installed• None currently identified• Various substitutes
including hydrocarbons• Semiconductorindustry•Electricity(substations)• Manufacturing(placesusing
high-voltagepower)3•No
replacements
currently identified•
Big
reductions
possible by means suchas using sealed systems
in factories•No
replacements
currently identified•
Big
reductions
possible by means suchas using sealed systems
in factories

Appendix 1

Scenario for Reducing Emissions of
the Three Gases in Japan•
HFCs, PFCs, and SF6 (the three gases) are powerful GHGs whose GWPs are at
maximum over 20,000 times that of CO2, and account for about 3% (CO2 equivalent) ofJapan's GHG emissions.
•HFCs should be replaced with natural substitutes, while PFCs and SF6, forwhich substitutes have not been identified, should be strictly controlled within factories.
If these two actions are taken, by 2010 it will be possible to reduce emissions of the threegases to one-third those of 1995 (CO2 equivalent; corresponds to a 2% cut in Japan's total
GHG emissions). In other words, although the Guideline of Measures to Prevent Global
Warming predicts that 2010 emissions of the three gases will be 2% over those of 1995, itis possible to be 2% lower.
•Current policy basically leaves reductions to voluntary industry plans, andsanctions HFC mass production. Especially if HFCs are used for insulation, emissions
will continue for the next several decades. The government should immediately overhaul
its policy of expanded HFC use, prohibit all new use of HFCs in insulation, refrigerants,and sprays, and institute strict controls on fugitive emissions of PFCs and SF6.

>> Basic Approach•
As HFCs have many substitutes, governments should reassess policies allowing
increased production and expanded use while depending only on recovery and destruction,and they should switch to policies aimed at reducing HFC production and use, such as byexpediting the transition to natural substances that can already be used.
•To deal with PFCs and SF6, for which substitutes have not been identified,
governments should switch to policies that avoid atmospheric releases by using completely
closed systems in factories, and subjecting recovered gases to the same strict control asPCBs.
•Taking the above two actions would make substantial reductions possible.
Producing, consuming, discarding, and then recovering large quantities of thesesubstances will allow their atmospheric emissions to continue over the next several
decades, and fail to solve the problem.

>> Emission Reduction Scenario•
CASA calculated the emission reductions possible in 2010 employing currently
available technology, basically using substitutes for HFCs, and strictly controlling PFCs
and SF6 in factories. We found that total emissions of the three gases can be reduced toone-third 1995 emissions (CO2 equivalent; corresponding to 2% of Japan's total GHGemissions).
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Table 1 Outlook for Reducing Emissions of the Three Gases
Units are millions of tons CO2 equivalent.
20103-gastotalHFCs
PFCs
SF61995

2000

2001

48.2

35.6

30.0

20.0
11.5
16.7

18.3
11.5
5.7

15.6
9.9
4.5

Guideline
BAU

Guidelinebased
measures

CASA'smeasures

7318107

Cuts achieved by
CASA's measures Remarks(1995 )
−63%

Corresponds
to2%ofJapan's total
GHGemissions>> Desirable Measures and Policy Actions•Outlined below are measures for totally phasing out HFCs, and policy actions forthat purpose. It is especially important to prohibit the use of HFCs in insulation, a newuse now being encouraged.

Table 2 Necessary Policies and Measures
FieldMain measures
Main policy actions• Cutting fugitive
HFC manufacture• Institute standards to curb fugitive emissions
emissionsAerosols (sprays,• Control HFC use in open systems (some medical• Prohibit use
fire extinguishers)
applications alone get temporary measures)• Control HFC use in open systems (includingInsulation• Prevent useinsulation)• Set time limit and• Limit HFC use in new refrigerators starting in
ban HFC use in2008
refrigerators
Refrigerants• Institute standards to control recovery rates and•RequireHFCamounts
recovery
Semiconductor• Require permission for use in machines (controlmanufacturing• Prohibit use in use of PFCs, etc. in open systems), instituteandcleaning open systems
standards to prevent fugitive emissions and(PFCs, SF6)
regulate recovery• Require permission for use in machines,
institute standards to prevent fugitive emissions• Reduce fugitive
Insulators (SF6)and regulate recoveryemissions• Institute standards to control recovery rates andamounts•
Additionally, in order to expedite substantial reductions in the use of the threegases, and the related substances (for example, the NF3 used in the semiconductorindustry) that are increasing rapidly these days, and to switch to natural substances, it isimportant to take other actions such as levying taxes proportional to substances' GWPs,and making those substances subject to pollutant release and transfer registers (PRTRs),
as well as expanding PRTR systems to show the public which sites are producing, storing,and emitting these substances, and their amounts.
5>> Summation•Producing, consuming, discarding and recovering large quantities of thesesubstances, as at present, will allow their fugitive emissions over the next several decades,and fail to solve the problem.
•If HFCs are used in insulation, the HFCs will be replaced by air and emitted into
the atmosphere over the next several decades. It is necessary to replace HFCs withalready existing natural substances instead of expanding HFC use into new applications.
Instead of relying on recovery alone, the government should immediately institute policies
and measures for a total HFC phaseout.
•In the auto air conditioner field, which accounts for much of Japan's refrigerantuse, there are reports that manufacturers are developing, or have completed developmentof, compressors for CO2 and hydrocarbon refrigerants. The government should institutepolicy actions that encourage such business efforts. It should also consider Denmark's
GWP tax, support for research and development, subsidies, tax incentives, and otherinducements.

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