Appendix III Comments From the U.S. Initiative on Joint See comment 3. Now on p. 4. See comment 4. See comment 5 Now on p. 5. Now on p. 7. See comment 6. Now on p. 8. See comment 7. Page 3 Suggest a footnote with the following: "The USIJI staff has acknowledged that it has not provided standard monitoring guidance to projects, nor reviewed monitoring plans for most projects since most projects are just beginning to be implemented and/or funded. USII is a pilot program that is evolving Monitoring of greenhouse gas emissions and verifying these reductions is work that still needs to be strengthened. The Environmental Protection Agency (EPA) has funded studies to develop standard methods for calculating project baselines and net emissions, specifically." 2 Para (insert the following sentence after the 1" sentence): Ground rules were developed in as interagency process, chaired by the State Department. 3" Para (edit 3′′ sentence to include): “The Clean Development Mechanism" to the list of marketbased approaches so that the key sentence at the end of the paragraph would read: “Such approaches include emissions trading, joint implementation and the Clean Development Mechanism." Page 10 1" Para (suggest inserting the following at the end of the first paragraph): USIJI staff explained that in this pilot program, especially in the early rounds, there were differences of interpretation of some of the criteria as applied to specific projects. This is part of the valuable learning process of the pilot program. The most difficult criteria in this regard relates to the concept of "additionality,” meaning the likelihood that the emissions reductions would not have occurred with out the project. Page 11 1a Para (suggest inserting the following at the end of the first paragraph): USIJI has streamlined its application procedures; the first and second rounds were conducted annually. Project developers expressed the need to have a quicker turnaround process, and for the last couple of years, USLJI evaluates proposals 3 times per year. The smallest number of proposals came in Round 4, which was the first after the change to shorter periods. Appendix III Comments From the U.S. Initiative on Joint Now on p. 9. Now on p. 13. Now on pp.18 and 19. Four other considerations should accurately reflect “exact” language in USIJI guidelines, not a 1) The potential for the project to lead to changes in greenhouse gas emissions elsewhere 5 participants are emitters of greenhouse gases him the United States underway within the host country to ratify or accade to the United ● Framework Convention ou Climate Ch to develop a national inventory and/or weline of greenhouse gas emissions by sources and removals by sinis, and whether the host country is taking measures to reduce its emissions and enhance its o serveire Appendix III Comments From the U.S. Initiative on Joint GAO Comments The following are GAO'S Comments on the letter from the U.S. Initiative on 1. Prior to the Kyoto Protocol, the term "joint implementation” generally 2. For increased readability, we have used the word Initiative rather than the acronym USUI when referring to the U.S. Initiative on Joint Implementation. This is explained in footnote 6 of this report. 3. This information appeared in the draft report provided to the Secretariat for comment and, in our judgment, belongs on page 14 of this report. 4. This information appeared in the draft report and, in our judgment, belongs on page 5 of this report. 5. This information appeared in the draft report and, in our judgment, belongs on page 6 of this report. 6. The draft report provided to the Secretariat for comment discussed the differences of interpretation of the criteria. We added footnote 11 to this report to provide additional information on the nature of the areas of "less than clear compliance" with the criteria as reported by the Secretariat in its comments. 7. The draft report discussed the increase in the number of evaluation rounds conducted each year as a reason for the small number of proposals submitted for evaluation in round 4. Based on the Secretariat's comments, Appendix III Comments From the U.S. Initiative on Joint we also included information on the reason for the change in the number of evaluation rounds the Initiative conducts each year. 8. The draft report provided in the text information on the frequency of the evaluation rounds conducted, and the dates of each evaluation round were provided in the table. Therefore, an additional note to the table is not necessary. 9. We determined it was not necessary to list the Initiative's criteria verbatim in the report. However, in response to the Secretariat's comments, we added an introductory statement to appendix I indicating that we have paraphrased the criteria and other considerations used by the Initiative's Evaluation Panel in evaluating proposals. |