(34) and Bulgaria (14). The track I projects are located in Germany, Hungary, Romania, New Zealand, France and Ukraine.<sup>10</sup> The number of JI projects is dwarfed by those in the CDM pipeline, which in June 2009 contained 4,417 projects. The disparity in the numbers between JI and CDM projects is partially attributable to the fact that the CDM enjoyed a “prompt start” authorized by the Conference of the Parties (COP) to the UNFCCC which allowed the registration of projects starting in 2001. This means that the CDM’s Certified Emissions Reductions (CERs) obtained during the period between 2000 and 2008 can be used to assist in achieving compliance during the first commitment period. JI on the other hand can only generate Emission Reduction Units (ERUs) during the first commitment period, namely between 2008 and 2012. While the CDM is managed or administered on the international level by a governance structure that is largely independent from host country performance, administrative capacities and GHG accounting frameworks, JI depends on emission limitation targets, allocation of AAUs, registries and the functioning of almost all other elements of the infrastructure of the Kyoto Protocol. Carbon credits generated by JI are nothing but AAUs in disguise, authorized for private trade, but generated by the host country which converts AAUs into ERUs based on the evidence of verified emission reductions. As a result JI is environmentally more robust than the CDM, but institutionally more vulnerable. It is also highly dependent on the functioning of domestic institutions: in order to participate in JI, countries have to fulfill a number of accounting requirements and compliance has to continue throughout the implementation of a JI project. Countries have to elaborate project approval procedures and be able to account for ERUs as part of their AAUs. Participation in JI also depends on political will. Until June 2009 the Russian Federation has not approved a single JI project. These delays strengthen the feeling that Russian JI projects will not deliver timely ERUs (PointCarbon 2008b; GTZ 2008a), or at least not at the expected scale. Other countries like the Netherlands have decided not to host any projects as a matter of principle in order to avoid the export of emission reductions.

As a consequence of the relatively small number of projects, the international administration of the track II stream of JI is less burdened and remains comparatively efficient. The fire of criticism that has been opened on CDM does not, or to a much lesser extent, apply to JI. NGOs pay little attention to the mechanism since environmental integrity is less of an issue as ERUs are technically not offsetting any emissions. The relationship between project participants, JISC and accredited independent entities (AIEs) responsible for determination of projects and emission reductions (the JI equivalent of CDM’s validation and verification) is characterized by a cooperative spirit. Identified problems, such as the delays in the accreditation of AIEs, are relatively quickly solved once they have been identified.11 If at all, JI is suffering from an unfortunate neglect, which may well change once its important role is fully understood in a post 2012 climate regime.

> 10 The data come for the UNFCCC website and the UNEP Risoe CDM pipeline.

> 11 The JISC modified the rules for the accreditation of IEs at its 13th session in Poznán, Poland, to overcome a bottleneck in the accreditation which would have hampered project validation for years to come. The problems had been identified by project developers and IEs and triggered swift action of the JISC.

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