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FOIA Number: 2017-1095-F
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Environment - Joint Implementation Climate Change
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20
5
7
1
GLOBAL CLIMATE COALITION
GROWTH GLOBAL )
sent 3/15 Emily te Alam K.
Fle (Soint
IN
A
Thursday, March 10, 1994
Mr. Joseph Stiglitz
Council of Economic Advisors
O.E.O.B.
Room 3145
Washington DC, 20500
Dear Mr. Stiglitz:
I am enclosing the Global Climate Coalition's comments submitted to the Department of
State on February 25 concerning Groundrules for U.S. Initiatives on Joint Implementation.
The Coalition is supportive of the concept of joint implementation. We believe if the joint
implementation pilot program provides a range of opportunities, U.S. industry can make a
constructive contribution, bringing benefits to the United States and to developing
countries.
For U.S. industry to participate actively and make its maximum contribution, it is essential
for the U.S. to develop flexible procedures for joint implementation. Such flexibility will
generate the efficiency, innovation and competition needed to further promote this
concept. We have sought to provide comments that would facilitate industry's
participation and contribution, and we hope they are useful to the Administration.
We have appreciated the opportunity to comment on the proposed Groundrules for Joint
Implementation and are looking forward to working with the Administration in the further
development of their concepts for this program. In that regard, we are very interested in
any information regarding the next steps the Government plans to take in shaping the
proposed pilot programs.
Sincerely,
Jor John Shlaes Ahlas
Executive Director
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1790
Telephone: (202) 637-3162
Fax: (202) 638-1032
Fax: (202) 638-1043
G LOBAL CLIMATE COAL T ON
GROWTH GLOBAL )
IN
A
GLOBAL CLIMATE COALITION MEMBERSHIP
Board Membership
General Membership
Aluminum Association, Inc.
American Commercial Barge Line Co.
American Automobile Manufacturers
Amoco Corporation
Association
Arizona Public Service Company
American Electric Power Service
Association of International Automobile
Corporation
Manufacturers
American Forest & Paper Institute
BP America, Inc.
American Iron & Steel Institute
Burlington Northern Railroad
American Mining Congress
CONRAIL
American Petroleum Institute
Consumers Power
American Portland Cement Alliance
Du Pont Company
Association of American Railroads
Eastman Kodak
Atlantic Richfield Company
Goodyear Tire & Rubber Co.
Chemical Manufacturers Association
LTV Steel Company, Inc.
Chevron
Norfolk Southern
Cincinnati Gas & Electric Company
Northern Indiana Public Service Co.
Council of Industrial Boiler Owners
Ohio Edison
CSX Transportation, Inc.
Pennsylvania Power & Light Company
Dow Chemical Company
Railway Progess Institute
Drummond Company
Shell Oil Company
Duke Power Company
Union Pacific Railroad
Duquesne Light Company
Edison Electric Institute
ELCON
Exxon
Illinois Power Company
Kaiser Aluminum & Chemical Corp.
National Association of Manufacturers
National Coal Association
National Lime Association
National Rural Electric Cooperative
Association
Phillips Petroleum Company
Process Gas Consumers
The Southern Company
Texaco, Inc.
U.S. Chamber of Commerce
Union Electric Company
1331 Pennsylvania Avenue, NW Suite 1500 - North Tower Washington, DC 20004-1790
Telephone: (202) 637-3162
Fax: (202) 638-1032
Fax: (202) 638-1043
G.OBAL CLIMA E COAL T ON
GROWTH
GLOBAL
February 25, 1994
Mr. Dan Riefsnyder
Director
Office of Global Change
Room 4329-A
Department of State
2201 C Street, NW
Washington. DC 20520-7818
Re: Notice of Availability of Groundrules for U.S. Initiatives on Joint Implementation,
58 Fed. Reg. 66057-59 (December 17, 1993)
Dear Mr. Reifsnyder:
The United States Government announced the U.S. Initiative on Joint Implementation
(USIJI) on October 19, 1993, as a pilot program to facilitate cost-effective greenhouse gas
reductions in other countries. The USIJI is a pilot program to help establish a basis for
joint implementation and is included in Appendix II of "The Climate Change Action Plan"
(CCAP) of October 19, 1993, submitted by the U.S. Government.
The U.S. Department of State published the draft Groundrules for U.S. Initiatives on Joint
Implementation (Groundrules) in the Federal Register on December 17. 1993, as the initial
step in developing the pilot program for Joint Implementation. Comments and questions
on the Groundrules were requested by January 25, 1994 and later the submission date was
extended until February 25, 1994.
In response to that request the following comments
are submitted by the Global Climate Coalition (GCC). The Global Climate Coalition is a
broad-based organization of business trade associations and companies representing virtually
all elements of United States industry, including the energy-producing and energy-consuming
sections. The Coalition was established in 1989 to coordinate business participation in the
scientific and policy debate on the global climate change issue. The members of the GCC
have been very active on the issue, and have participated in the United Nations Conference
on Environment and Development in Rio de Janeiro, legislative debates in the Congress,
the United Nations Framework Convention on Climate Change deliberations, and the
development of the 1992 U.S. National Climate Change Action Plan. A list of the GCC
membership is attached.
1331 Pennsylvania Avenue, NW Suite 1500 - North Tower Washington, DC 20004-1790
Telephone: (202) 637-3162
Fax: (202) 638-1032
Fax: (202) 638-1043
General Comments
Support for the Concept of Joint Implementation: The Global Climate Coalition has
expressed enthusiasm for and continues to be supportive of the concept of Joint
Implementation referenced in the Framework Convention on Climate Change (FCCC) and
elaborated on in the Administration's Climate Change Action Plan of October 19. 1993. We
believe it is appropriate for national governments to begin to assess potential programs and
procedures for Joint Implementation through pilot programs that will help to define
efficient, effective means to implement the concept nationally and internationally and we
encourage the U.S. Government to maintain its lead in this effort.
While the Global Climate Coalition does not believe that rigid targets and timetables are
called for, the Action Plan's approach of working through voluntary business/government
partnerships and initiatives is fully responsive to the requirements of the Convention and
is superior to an emphasis on traditional command-and-control mechanisms, such as
regulations. The latter would most certainly be economically disruptive and could put U.S.
business and industry at a competitive disadvantage with business and industries in other
countries whose National Action and Joint Implementation plans and assumptions may
differ from ours. Joint Implementation should not discourage collaborative projects that
make both economic sense and reduce greenhouse gas emissions.
Support for Action in Developing Countries by Industry: The GCC supports the proposed
Joint Implementation program's focus on promoting collaboration with any country,
especially developing countries and countries whose economies are in transition.
Developing countries and the former centrally planned economies emit a far greater volume
of greenhouse gases for each unit of their GDP than the United States. Four-fifths of the
world's people live in developing countries today, and most of the population, economic and
energy demand expansion--and the resulting greenhouse gas emissions--are projected to
occur there, as their population is expected to represent 90 percent of the world's population
growth in the coming decades. The 1992 supplemental report of the Intergovernmental
Panel on Climate Change indicated that 68 percent of the total energy related CO₂
emissions will come from non-OECD (Organization of Economic Coordination and
Development) countries by 2025. For this reason, to the extent that actions may be
required, developing country participation in climate change activities will become a growing
necessity.
Likewise, the GCC strongly favors a joint implementation approach that promotes active
participation by private industry. Many of the current activities of U.S. industry abroad are
fully compatible with the joint implementation concept, and we suggest that some
consideration be given to possible ways and means for ongoing projects to be incorporated
into the new initiative.
We believe that U.S. business and industry can contribute to and benefit from participation
in joint implementation, which helps identify new markets and strong overseas partners,
2
promotes the exchange of technology and valuable information, reduces costs, brings sound
rates of return on investment, and offers opportunities to diversify and obtain other
commercial benefits through cooperation with both government and private partners
abroad.
Encourage Free and Open Program Approaches: The Coalition believes its members can
make this contribution and receive these benefits best if the joint implementation program
is structured so as to encourage use of market economy mechanisms and open and
transparent procedures. We believe that free and open markets will generate the efficiency,
innovation and competition needed to promote joint implementation. Additionally, they
spawn unrestricted exchange of information and know-how that are essential for successful
collaboration.
We believe that over-regulation and use of command-and-control regulations will be most
harmful to our members' participation in the program, and we would strongly urge that such
approaches not be employed in this new program. Transparent and fairly enforced criteria,
rules and procedures are essential. And increasingly as we are finding in our domestic
programs, reliance on market incentives rather than regulations is to be encouraged, as is
close cooperation between government and industry in the conduct of the program. We
strongly encourage the U.S. Government to seek to develop such a program nationally and
promote the same internationally. Such an approach is fully consistent with the worldwide
trend toward the use of free markets, which the U.S. Government and other industrialized
countries are promoting.
Because the world community will have little experience with joint implementation, it is
essential for the U.S. to advocate flexible procedures for joint implementation under any
rules to be developed by the Conference of the Parties, at least until sufficient experience
is gained to make more detailed recommendations for international procedures.
If the program is developed in this way, the GCC is confident that joint implementation will
receive strong industry support and provide natural benefits to our overseas partners, while
making a contribution to reducing emissions of greenhouse gases and promoting technology
cooperation and sustainable development called for in the Convention and Action Plan.
Specific Comments on the Groundrules
Within the context of the above general comments, we have a number of specific comments
on the draft Groundrules, as follows:
Section 1 - Purpose: We find the statement of the proposed pilot program consistent with
the Framework Convention. We believe the reference to "mutually voluntary projects
between U.S. and foreign partners "and "promoting technology cooperation "(Section
1(1)) to be valuable for industries' participation, and we welcome the reference to
"encourage private sector investment and innovation "(Section 1(4)).
3
However, we are concerned about the reference to "net emissions" (Section 1(1)) and the
many subsequent references to that term throughout the Groundrules. While we understand
the relevance of net reductions of greenhouse gases as they relate to a Party to the
Convention, we do not see their appropriateness for the individuals or entities conducting
individual projects in the pilot program. Each joint implementation project must be
considered on its own merits and not with regard to its relationship to the cumulative
emissions of any parties to the Convention. Since one of the principal benefits of a joint
implementation project is its potential for cost-effective emission reductions, the appropriate
measure of a project is the "savings" in emissions that it reduces, avoids or stores. Thus,
GCC suggests that the term "net emissions" be removed in the case of a project and that a
project be evaluated, among other things, on the basis of emissions of greenhouse gases that
it reduces, avoids or sequesters.
Section 2 - Evaluation and Reassessment of Pilot Program: We believe the timing for the
evaluation of the pilot program is not properly synchronized with the schedule of
international events. The Groundrules call for the USIJI to be "evaluated within two years
of its inception." However, under the schedule of international events, the evaluation will
not occur until the fall of 1995. following the adoption of the international criteria. For the
U.S. program to be used in the formulation of the international criteria, it would seem that
an initial evaluation of the program should occur in December 1994. It is, of course,
recognized that there may not be much experience available at that time. Yet evaluation
should be made on what has been learned. Hence, it would seem to be appropriate for the
Groundrules to call for an interim report at least in December 1994.
Section 3 - Eligible Participants: In Section A.(2) Domestic we believe it would be clearer
to expand the definition as follows: "Any company, organization, group, or combination
thereof, incorporated under or recognized by the laws of the United States." We would
request a similar formulation under B.(3) Foreign,
Section 4 - Evaluation Panel: We believe the most relevant U.S. Government agencies are
included in the Evaluation Panel membership. However, whether there should be reference
to and linkage with other U.S. Government agencies and programs that could be essential
to a successfully coordinated U.S. Program. We refer specifically to important financial
assistance organizations such as the Export-Import Bank and the Overseas Private
Investment Corporation, the Commodity Credit Corporation's debt-equity or debt-for-nature
activities, or initiatives such as the Enterprise for Americas Program and the like. We refer
as well to the technology transfer initiatives of the Department of Commerce and the U.S.
Environmental Protection Agency and others, such as the U.S.-Japan Program, to promote
environmental and energy technologies. We do not see a need for representatives of such
organizations to become Panel members, but we believe that the Panel should be linked
to their work and, perhaps, a reference to "other relevant departments, agencies and
programs" should be made to ensure this.
There is no consideration of non-governmental members to join in the work of the Panel.
4
Inasmuch as most of the work on the Joint Implementation is likely to be undertaken by
non-governmental entities, this absence seems unwise. We recognize that many non-
governmental entities will want to participate and that selection would be difficult.
Nonetheless, since industry will very likely be the major participant in the program, we
would suggest that industry representatives should have the opportunity to participate in the
panel's proceedings.
Section 4(C)(6) says the Panel is responsible for "certifying net emissions reductions
estimated to result from projects." Besides our general disagreement with the "net
emissions" formulation. it is not clear in this case what "certifying" means. Since it appears
to be covered in Section 4(C)(4) on approval. we believe this article should be dropped
altogether. The information and methodology provided by the project applicants should be
used and reviewed by the Panel in deciding upon the project approval.
Section 5 - Criteria: In line with our general comments that industry will more readily and
easily participate in activities in foreign countries if regulations and requirements are
reduced to the essential minimum, the criteria should be limited and simple and the
Evaluation Panel should be given maximum flexibility in reviewing project submissions. In
this vein the "must find" in Section 5(A) should more appropriately read "shall consider."
Criterion 5 A.(1) says the project "isaccepted by the government of the host country."
We believe it will be essential for governments to agree and to make known who (what
agency or combinations of agencies) is the "host government." GCC members have
frequently received conflicting information on who represents governments on specific
activities. Again, it is very important for industry that the requirements for governmental
acceptance or approval are not so onerous and costly as to discourage participation.
Criterion 5A.(2) needs greater clarification as to the "data and methodological
information" and "current" and "future" emissions. Will this be measured against a baseline?
Again. we would delete the "net" before "greenhouse gas emissions."
Finally, it is not clear to us how this criterion would apply, for example, to projects
conducted in sites where there were no corresponding pre-project emissions and where the
emissions avoided would be the difference between emissions from the new project versus
what they would have been using less efficient technology.
Criterion 5A.(3) requires more explanation for clarity. As indicated earlier, we would
delete the "net" before "reductions in greenhouse gas emissions." We believe the final
passage on "funds in excess "on fiscal year 1993 is designed to meet "new and additional
funding" requirements and would apply only to U.S. Government-funded activities.
Criterion 5A.(4) refers to "adequate measures for tracking the actual greenhouse gas
emissions resulting from a project." It refers again to "net" greenhouse gas emissions, which,
as we have indicated earlier, do not seem appropriate for projects. We believe tracking is
5
necessary to ensure that projects are proceeding as desired and expected. Once again, it is
our belief that simplicity and flexibility should govern such tracking procedures. The present
description under this criterion is inadequate to determine what the requirements will be,
and thus better definition should be provided.
Criterion 5A.(5) calls for "external verification" of a project. As already observed,
the term "net" should be removed. Additionally. the meaning of "external verification" needs
specific definition. Inasmuch as governments accept the project, who would be considered
"external" to verify a project? And what would be involved in "verification"? It would
appear that the information needed for a review of the project would already be provided
under Criteria 5A.(1) through (4); what additional information would be required? GCC
would certainly be concerned if external verification were conducted by sources outside the
government, other than the project participants themselves. and if it would involve disclosure
of inappropriate information or seek to elicit commercially confidential information or
information that compromises intellectual property rights.
Criterion 5A.(6) calls for identifying any associated non-greenhouse gas
environmental impacts/benefits. We would hope that this does not become a disguised
Environmental Impact Statement procedure for the project, which might be extraordinarily
burdensome and could be unacceptable to foreign governments and industries. Again, we
believe further definition and simplicity of implementation relating specifically to the project
is urged.
Criterion 5A.(7) provides for "assurances that net greenhouse gas reduction benefits
accumulated over time will not be lost or reversed." "Net" should be deleted. Additionally,
GCC finds it difficult to understand how "assurance" would be given. There may well be
alterations in a project that will change results, and adjustments could be made. Moreover,
as the projects will be conducted in a foreign sovereign jurisdiction, it may not be possible
for a U.S. participant to provide an assurance beyond intent. Also, the meaning of "over
time" needs further definition. There is a distinction between the kinds of assurances that
can be given over the course of an energy efficiency project and those for an afforestation
project, and we do not see clearly how this criterion would be implemented.
Criterion 5A.(8) says projects accepted must be registered in the national inventory
established under Section 1605 of the Energy Policy Act of 1992. It should be noted that
participation in the 1605(b) program is voluntary; here the proposed Groundrules seek to
make them mandatory. This is not appropriate. It should also be noted that the 1605(b)
reporting would only apply to United States entities and not to foreign entities; some
consideration then must be given to this and to how common, harmonious reporting of a
project in a foreign country may be achieved. Having said this there is value in making the
Groundrules consistent with the 1605(b) guidelines since there should be machinery for
assuring consistency in reporting within the U.S. Climate Change Action Plan and ultimately
within the agreed international program.
Also, GCC notes that the guidelines for
reporting under Section 1605(b) do not now exist. The Department of Energy and the
6
Environmental Protection Agency are developing guidelines but they will not be finalized
until next fall, and the Energy Information Administration will not publish forms until six
months later. Under the present formulation of the joint implementation guidelines,
projects cannot be approved until 1605(b) guidelines exist. We believe some adjustment
must be made to take account of the timing differential of the availability of the 1605(b)
guidelines.
Criterion 5A.(9) provides for "annual reports to the Evaluation Panel on the actual
reduction achieved in net greenhouse gas emissions and on the share of such reduction
attributed to each of the participants. " As stated earlier GCC believes "net" should be
deleted. Also, GCC does not believe that many private participants will be able to
determine or report on shares of reductions for purposes of USIJI, since it is mainly
governments which are informed about and reporting on shares to demonstrate compliance
with their national commitments to reduce greenhouse gas emissions. GCC believes that
annual reporting to the Panel on the status and progress of a project is appropriate, but
suggests that such reports be incorporated into a simple format report incorporating the
other criteria requirements of Section 5A.
Section 5B. This section lists factors that the Evaluation Panel "shall also consider"
in including projects under USIJI. GCC finds that many of these criteria are vague, open
ended, and go well beyond the information that is legitimately needed to evaluate a project.
In addition, some of the information would be available only to host governments. Specific
comments are as follows:
Section 5B.(1) calls for information on "the potential of the project to lead to net
changes in greenhouse gas emissions elsewhere." Again, we request deletion of the word
"net." Additionally, for project participants to have or be able to obtain information
"elsewhere" is questionable and would not seem necessarily relevant to participants in the
project. As it might be valuable for governments, they should be requested to provide it,
not private project participants.
Section 5B.(2) requests information on "the potential positive and negative effects of
the project apart from its effects on net greenhouse emissions." Again we request "net" be
deleted. We also believe this is much too sweeping a requirement to include in the
program. It goes well beyond environmental effects, called for in criterion 5A.(6), and could
encompass a wide range of issues which go well beyond those needed for joint
implementation. Indeed, this could become a disincentive to private sector participation in
joint implementation. We believe this criterion should be clarified and narrowed to specific
information essential for consideration of joint implementation projects.
Section 5B.(3) asks whether U.S. participants are net emitters of greenhouse gases
within the United States and, if so, whether they are taking measures to reduce such net
emissions. GCC believes this information is completely irrelevant to evaluating the merits
of a joint implementation project abroad and should be deleted.
7
Section 5B.(4) requests information on ratification and other measures related to the
Framework Convention on Climate Change by the host country. This, GCC believes, is
appropriate for governments to obtain and know, but is not necessarily information that
private project applicants will have access to. nor should it be relevant to the merits of a
joint implementation project. It should be deleted as a criterion for joint implementation
project acceptance.
Final Comments
As our General Comments and Specific Comments make clear, the Global Climate
Coalition supports the concept of Joint Implementation, believing it can contribute to the
U.S. goals to implement the Framework Convention on Climate Change while benefiting
developing countries and others, including business and industry. The extent to which
business and industry will be effective participants depends on the policies and procedures
developed to realize Joint Implementation in actual programs nationally and internationally.
We emphasize that our participation will be facilitated if the program is kept uncomplicated
and transparent and formulated as nearly as possible to be consistent with the ways in which
business and industry most effectively work internationally while, of course, meeting the
goals of the program. We have designed our comments to help achieve this.
This brings us to comment on several matters to which the Groundrules do not refer but
which we believe will be essential to a successful Joint Implementation Program involving
maximum participation of the private sector.
There is the need to establish a clear and active focal point to manage the program,
integrate the contributions of U.S. agencies, and to assist private sector participants to take
part in the most constructive manner possible. The establishment of a small government
staff could help to manage the U.S. involvement in joint implementation and could work
closely with U.S. participants, including business and industry, to facilitate their active
participation. The small staff could also assist in finding ways to reduce the many
impediments that exist when initiating and implementing projects and activities in other
countries.
We also foresee the need for broad information exchange on the program itself, on the
types of projects that are being undertaken, and on the needs of host countries. A
clearinghouse function for the staff would seem necessary.
Additionally, we think this staff could facilitate communications among those government
agencies whose activities could contribute to the program and urge them to give priority to
joint implementation. The staff could encourage agencies and programs which provide
governmental and international sources of funding to find ways to participate in the joint
implementation work.
The staff could also assist in coordinating both private and governmental activities which are
8
not necessarily part of joint implementation per se. but essential to its success, e.g., training
and capacity building in recipient countries. transfer of technology and the like.
Additionally, business and industry's participation will be facilitated through active
involvement in an orderly development of the Joint Implementation program. In this
respect the GCC continues to be concerned over the timing and the possibility of premature
decisions on the Joint Implementation Program and the Administration's Climate Change
Action Plan (CCAP) in general. The GCC is concerned that many CCAP programs will
have barely begun and some will not yet be underway when the CCAP will be revised and
incorporated into the National Action Plan and submitted to the Conference of the Parties
by September 1994.
We are also concerned with the CCAP's requirements for a task force to make initial
recommendations by the end of 1994 for a long-term strategy to reduce greenhouse gas
emissions after the year 2000. The GCC supports the use of a long-term strategy as a sound
planning tool. but we believe it would be premature to propose additional specific strategies
or targets for reducing greenhouse gas emissions before the scientific implications associated
with greenhouse gas emissions reductions strategies are better understood and before the
economic implications of the CCAP are known. The plan's requirement that a task force
make initial recommendations by the end of 1994 should be modified to delete reference
to 1994, and to include principally a flexible strategy which can be adjusted periodically and
as appropriate to fit the scientific and economic studies as they are produced.
The Global Climate Coalition appreciates the opportunity to comment on the proposed
Groundrules for the U.S. Initiative on Joint Implementation and looks forward to being
given the chance to work closely with the U.S. Government in the months ahead as the
proposed pilot program is further developed.
Sincerely
Executive Director
9
07/21/93 12:14
202 638 1043
GCC
001/004
GLOBAL CLIMATE COALITION
GROWTH GLOBAL )
IN
A
F crough (Joint Climite Implenate
Chinge)
July 21, 1993
Mr. Joseph Stiglitz
Member-Designate
Council of Economic Advisors
17 & Pennsylvania Ave., NW
Room 315
Washington, D.C. 20500
Dear Joseph:
I thought you might be interested in the attached letter on joint implementation.
Sincerely,
Dr John Shlaes
Executive Director
1331 Pennsylvania Avenue, NW
Suite 1500 - North Tower
Washington, DC 20004-1703
Telephone: (202) 637-3162
Fax: (202) 638-1043
Fax: (202) 638-1032
07/21/93
12:15
202 638 1043
GCC
002/004
GLOBAL CLIMATE COALITION
ENVIRONMENT
GROWTH
IN
A
GLOBAL
July 19, 1993
Mr. Thomas F. McLarty
Chief of Staff to the President
The White House
1600 Pennsylvania Avenue, N.W.
Washington, D.C. 20500
Dear Mr. McLarty:
Over the next several weeks you and other officials of the Administration will be
making decisions regarding policies to meet the goals announced April 21 by President
Clinton when he said:
"Today, I reaffirm my personal, and announce our nation's commitment, to
reducing our emissions of greenhouse gases to their 1990 levels by the year
2000."
"I am instructing my administration to produce a cost-effective plan by August
that can continue the trend of reduced emissions. This must be a clarion call,
not for more bureaucracy or regulation or unnecessary costs, but instead, for
American ingenuity and creativity, to produce the best and most energy-efficient
technology."
This is indeed a challenge as the decisions that you will make will effectively drive
energy and economic policy in our country for years to come. Members of the Global
Climate Coalition have been pleased to participate in the series of workshops which have
been held to discuss options available to meet these goals and want very much to
continue to work with you as you develop the plan and prepare to implement it.
We urge you to include options in the plan only after a careful analysis of their costs
and possible effects on our domestic economy and employment. And, we urge you not to
foreclose an option which could, if properly defined without overly restrictive parameters,
prove to be the most cost effective and best option available, the option of joint
implementation.
This concept - as yet to be precisely defined - was included in the Framework
Convention on Climate Change as a means to facilitate economic development in
developing countries while containing the growth in global greenhouse emissions by the
most cost effective means. The way that joint implementation will work domestically
cannot be determined at this point as it will depend in large part on the way that the
1331 Pennsylvania Avenue, NW
Suite 1500 - North Lobby
Washington, DC 20004-1703
07/21/93
12:15
202 638 1043
GCC
4
003/004
Mr. Thomas F. McLarty
July 19, 1993
Page 2
international definitions are constructed by parties to the framework convention. This
will not be resolved for some time. The drafters of the convention, however, clearly
recognized that pursuit of joint implementation programs to achieve net greenhouse gas
emissions reductions in developing countries would be regarded as just as significant as
domestic reductions of emissions and should be given equal consideration.
Properly defined, joint implementation can meet several goals as it can:
help address environmental and economic challenges that already exist in developing
countries (including countries with economies in transition), where the opportunities
for reducing the rate of growth in greenhouse gas emissions far exceed that in the
mature, efficient economies of developed countries;
reduce greenhouse gas emissions globally at a lower cost than domestic controls;
create new job opportunities for U.S. industry by deploying technological and
managerial expertise in countries where it is desperately needed;
lead to long-term economic development by accelerating the advancement and
utilization of more efficient energy technologies with reduced environmental
impacts.
We understand that there is a debate within the Administration as to whether joint
implementation should be a part of the August National Action Plan and the options put
forth at that time. We hope that you do not foreclose this option which could be
effective in the short term as well as over a longer term in reducing global emissions.
Because of population growth the legitimate and understandable desire for economic
progress in the developing countries will lead to rapid growth in greenhouse gas
emissions in these nations, and reductions in greenhouse gas emissions made in the U.S.
or other OECD nations will be quickly overwhelmed. This rate of growth could be
reduced by a program of technological cooperation between OECD nations and
developing countries. Alternatively, if this option is foreclosed the financial capability of
OECD nations to assist these countries in their quest for a better economy could be
hampered.
The benefits that can accrue to this nation and the world by a well structured policy of
joint implementation cannot be underestimated. A national action plan focused solely on
domestic programs could threaten the continued economic growth and competitiveness
of the U.S. economy. A plan that combines cost effective domestic measures, including
voluntary measures, with a properly defined joint implementation program, could foster
this nation's economic growth and international competitiveness while providing the
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Mr. Thomas F. McLarty
July 19, 1993
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means for the developing countries to enjoy a level of prosperity and environmental
protection that has heretofore eluded them.
There is still substantial scientific uncertainty regarding whether global climate change
is occurring and if so how fast and what impacts might be. The members of the Global
Climate Coalition support actions to reduce greenhouse gas emissions or to increase
greenhouse gas sinks that are justified for other economic or environmental reasons. If
properly defined joint implementation can be one of those actions. We stand ready to
assist you in your efforts.
Sincerely,
Oxhlan John Shlaes
Executive Director
cc: Interagency Climate Change Mitigation Group
Interagency Analysis Team