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B-279654

Agency Comments

in emissions would likewise not have occurred, called emissions
additionality.

Some phases of the research have been completed and are undergoing review, while other phases are continuing. According to EPA officials, standard methods for estimating emissions reduction benefits would help to move the program from its current pilot phase to a fully implemented program with credible reductions. The officials were not able to say how long the development of the standard methods might take, but current studies being funded by EPA are to be completed during this fiscal year. An EPA official also said that the agency is currently funding research on methodologies for monitoring and plans to fund research on methodologies for verification in the future. (App. II provides additional information about efforts to develop standard methods.)

We provided a draft of this report to the Director of the Joint Implementation Secretariat and the Administrator of EPA for review and comment. The Secretariat's Director said that the report is generally a balanced assessment of the Initiative, with a useful analysis of the projects and the consideration of those projects by the Initiative's Secretariat and Evaluation Panel. (The Secretariat's comments and our responses appear in app. III.) The Director also suggested technical corrections to the draft report, which were incorporated as appropriate. EPA's Office of Economy and Environment, within its Office of Policy, Planning and Evaluation, also suggested technical corrections, which were incorporated as appropriate.

To accomplish our objectives, we interviewed officials of the Initiative's Secretariat, EPA, and the Department of State. At the Secretariat offices, we obtained and reviewed information pertaining to the Initiative's project evaluation process, including policy memorandums, technical review summaries of project proposals, and decision memorandums prepared to assist the Evaluation Panel with its decision-making process. At EPA, WE obtained and reviewed information related to its efforts to develop standard methods for measuring greenhouse gas emissions and for estimating projects' emissions reduction benefits. At the Department of State, we obtained information on the development of the ground rules for the U.S. pilot program and public comments on notices published in the Federal Register. We limited our work on the third objective (relating to the status of approved projects) to those approved in the first round because they had had the longest period of time to be developed. This

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information was obtained by reviewing the latest annual reports prepared by the participants in the accepted projects. The Secretariat staff assisted us in obtaining information from the project participants when information contained in the reports was not clear. We did not independently verify the information provided by the Secretariat.

We also reviewed available documents about the joint implementation concept, the U.S. Initiative, and the United Nations' pilot program. We conducted our review from September 1997 through June 1998 in accordance with generally accepted government auditing standards.

As arranged with your office, unless you publicly announce the report's contents earlier, we plan no further distribution of this report for 15 days. At that time, we will send copies to the appropriate congressional committees, the Director of the Secretariat, and the Administrator of EPA. We will also make copies available to others upon request.

Major contributors to this report were David Marwick; Stacy L. Morgan; William H. Roach, Jr.; and Robert D. Wurster. If you have any questions or need additional information, please call me at (202) 512-6111.

Sincerely yours,

Peter F. Guerrero
Director, Environmental
Protection Issues

Appendix I

Criteria and Other Considerations Used in
Reviewing and Evaluating Proposed

Projects

These criteria and other considerations were published in the June 1, 1994, Federal Register (Vol. 59, No. 104, pp. 28445-28446). They are paraphrased below.

Criteria

Other Considerations

1. Is the project acceptable to the government of the host country?

2. Does it involve specific measures to reduce or sequester greenhouse gas emissions initiated as a result of the U.S. Initiative on Joint Implementation or in reasonable anticipation of the Initiative?

3. Does it provide data and methodological information sufficient to establish a baseline of current and future greenhouse gas emissions, both with and without the project?

4. Will it reduce or sequester greenhouse gas emissions beyond those without the project, and, if the project is federally funded, is it or will it be undertaken with funds in excess of those available for such activities?

5. Does it contain adequate provisions for tracking the greenhouse gas emissions reduced or sequestered as a result of the project and, on a periodic basis, for modifying such estimates and comparing actual results with original projections?

6. Does it contain adequate provisions for external verification of the greenhouse gas emissions reduced or sequestered by the project?

7. Does it identify any associated non-greenhouse-gas environmental impacts and benefits?

8. Does it provide adequate assurance that the greenhouse gas emissions reduced or sequestered will not be lost or reversed over time?

9. Does it provide for annual reports to the Evaluation Panel on the emissions reduced or sequestered and on the share of such emissions attributed to each domestic and foreign participant, pursuant to the terms of the voluntary agreement among the project's participants?

1. Does the project have a potential to lead to changes in greenhouse gas emissions outside the project's boundaries?

Appendix I

Criteria and Other Considerations Used in
Reviewing and Evaluating Proposed
Projects

2. Apart from the project's effect on greenhouse gas emissions, does the project have any potential positive and negative effects on factors such as local employment and public health?

3. Are U.S. participants who are emitting greenhouse gases within the United States taking measures to reduce or sequester those emissions?

4. Does the host country have efforts under way to (1) ratify the United Nations Framework Convention on Climate Change, (2) develop a national inventory and/or baseline of greenhouse gas emissions and sinks, and (3) reduce its emissions and enhance its sinks of greenhouse gases?

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