In-Depth Review of Japan’s Third National Communication Under the United
Nations Framework Convention on Climate ChangeDecember 5, 2002
Yurika Ayukawa
Climate Change Policy Senior Officer
World Wide Fund for Nature (WWF), JapanPreamble
Japan ratified the Kyoto Protocol on June 4th, 2002.

In order to ratify, the government

laid out plans to reduce 6% GHG emissions from 1990 level as stipulated in the Kyoto
Protocol. However the plan does not include any real policy or measures or any teeth
to guarantee the reduction. We are deeply concerned that Japan will not be able tomeet the 6% target of the Kyoto Protocol.

I would like to elaborate this concern on thefollowing three points, 3.9% from sinks, 1.5% from individual’s voluntary efforts, and1.6% from using the Kyoto Mechanisms.
1. 3.9% from Sinks Activities
Japan plans to absorb 13 MTC (equivalent to 3.9% of the 6% target) from forest
management.

This itself is a means to avoid real reduction from sources, and webelieve Japan should not be dependent on sinks to achieve the target, sincesequestration by forests is unreliable due to uncertainty of data, non-permanence,leakage, and difficulty in separating human-induced activities to non-human-induced
ones.

These issues are still under negotiation by the parties, and so we should wait

for the outcome of the discussion to find ways to deal with the problems before starting
to count up amount of potential sinks in Japan.

This is because all these problems arerelevant to all sinks activities whether domestic or international.
On another front, the Japanese forests have been neglected for a long time due to highlabor costs and as a result, there had only been little forest activities for the pastseveral decades.

Consequently, there is less potential to account for forest

management activities than expected.

Even the government admits in its national

communication that under current situation in Japan, it may be difficult to count theamount of sinks up to 13 MTC.
What is now needed are policies to support and promote forestry industry, so that
forests would be cut and utilized, and planted again to make a living forest cycle. For
example, obligating newly built houses or public buildings to use certain percentage ofdomestic wood, establish a system to use wood-origin biomass for power and heatgeneration, tax incentives to produce, buy and use domestic wood for houses andfurniture.
Such policies should be made by joint work of all related ministries, but as a matter offact, only the Forestry Agency is appointed to acquire 3.9% from domestic forests.
2. Individuals to make Voluntary Efforts to reduce 1.5%
The general public is asked to make efforts to account to 1.5% reduction by, for example,
families spending time together in one room, refrain from watching TV one hour,refrain from using shower 1 minute everyday by every person, change light bulbs tofluorescent ones, replace microwave ovens to energy efficient ones, etc.

However,

there is no policy to mobilize the public to do so, such as subsidy or tax incentives tobuy energy efficient appliances, energy efficient labels to inform the consumers what
appliances to buy, nor regulation for lightings, wall insulators, double windows, ormanufacturing standards for air conditioners and heaters to avoid over-cooling orover-heating.
Efforts of the general public without any policy cannot be counted, and should not be
part of the reduction plan to achieve any target figure.

Efforts of the public arenecessary and effective, and the reductions should be counted as an additional
reduction, apart from the original reduction plan which should be made to achieve the6% target without this type of general public participation.
3. 1.6% by Kyoto Mechanism
Even with all the measures the government could think of, there is still a 1.6% gap
between the target.

The government plans to fill the gap using the Kyoto Mechanism.

But here again, the government does not give any incentives to mobilize the private
sector, such as tax incentive, subsidy, or a system to buy up credits earned throughprojects abroad.

Instead they succeeded in having a Japanese representative, Mr.

Okamatsu appointed as a member of the CDM Executive Board.

Through him andthe many Japanese companies applying for Operational Entities, Japan is seeking tomake the CDM/JI rules favorable to Japanese companies, only from economic rationale

point of view.

And the Japanese corporations are interested to acquire credits to sellin the international credit trading market system to make profits.

This is quite

worrisome, as the reduction through the Kyoto Mechanism may become much larger
than expected, as there is now no prospect for more new nuclear power plants, norcertainty to achieve 3.9% by sinks, and no guarantee to achieve 1.5% by the generalpublic.

The government prepared a “Kyoto Mechanism Guidebook” for the industries,

some part of which are misleading.

Some of our concerns are:ODA
One of the big concerns we have is that Japanese government has not ruled out ODA.
The Kyoto Mechanism Guidebook says that you will have to prove that the use of
public finance is not a “diversion of ODA” as written in the Marrakech Accord.
However according to the Japanese government’s explanation of ODA, the amount isdecided every year and thus it is “new” and “additional” each year. In such a context,
all projects with ODA financing will be approved as “no diversion.”
Project Additionality
The Kyoto Mechanism Guidebook only refers to emission reduction additionality andnot project additionality.

It says, it could be said as additional if there is additionalemission reduction compared to the case without the project.

What this means is that

Business as Usual projects could be defined as “additional” since it could makereduction which could not have occurred in the absence of the project. This would leadto increase in domestic emissions from BAU projects that would have occurred anyway.
Environmental and Social Impact assessment
The Kyoto Mechanism Guidebook says the project should comply with the legal
requirements of the host country and there is no need to do any more than what isrequired.

In countries with weak environmental protection law or in the absence ofany social impact assessment requirement, projects may be approved accordingly.
Japanese corporations have carried out a number of environmental destructive projects
in the developing countries to date, some of which are still under local disputes andoppositions.

We strongly ask the Japanese government to take rigorous position toensure that all Kyoto-related projects are strictly additional to make emission
reductions and that they are environmentally sound and socially acceptable. One of thetools WWF suggest is to introduce a carbon label system in which good projects that
benefits the environment are labeled as Gold Standard and encourage host country
governments to accept only those projects.
Attachments: WWF Scenario for Solving the Global Warming Problem, Fact Sheet for Gold Standard