European Commission: DG Environment EU Climate Change Policy Jürgen Lefevere International and...

European Commission: DG Environment

EU Climate Change PolicyEU Climate Change Policy

Jürgen Lefevere

International and Institutional Coordinator

Climate, Ozone and Energy Unit

Environment Directorate General

European Commission, Brussels


OverviewOverview

The Commission’s Communication “Winning The Commission’s Communication “Winning the Battle Against Global Climate Change”the Battle Against Global Climate Change”

The EU’s response to Climate ChangeThe EU’s response to Climate Change

EU Emissions Trading (EU ETS) and its link EU Emissions Trading (EU ETS) and its link with the Kyoto Mechanismswith the Kyoto Mechanisms

““post-2012” – “post-Montreal”post-2012” – “post-Montreal”


The EU’s post-2012 strategyThe EU’s post-2012 strategy

The Climate Challenge Benefits & costs The Participation

Challenge The Innovation Challenge The Adaptation Challenge

“Winning the Battle against Global Climate Change”9 February 2005


The importance of the 2The importance of the 2°C target °C target

22°C°C


““Millions at Risk”Millions at Risk”


Approx. annual mean surface temperature Approx. annual mean surface temperature distribution for a global increase of 2distribution for a global increase of 2°C°C


The probability to reach the 2°C targetThe probability to reach the 2°C target


EU international climate policy: Winning EU international climate policy: Winning the battle against climate changethe battle against climate change

Five essential elements:Five essential elements:1.1. Build on KyotoBuild on Kyoto2.2. Broaden participation Broaden participation 3.3. Include more sectors and Include more sectors and

all gasesall gases4.4. Deploy and develop Deploy and develop

technologiestechnologies5.5. Adapt to the effects of Adapt to the effects of

residual climate changeresidual climate change


11stst element: Build on Kyoto element: Build on Kyoto

Build a truly global carbon marketBuild a truly global carbon marketEmissions tradingJoint ImplementationClean Development Mechanism

Clear rules for monitoring and reportingClear rules for monitoring and reporting Multi-lateral compliance regimeMulti-lateral compliance regime


22ndnd element: The top 25 ‘climate footprints’ element: The top 25 ‘climate footprints’

S. Arabia

Top 25 in Emissions

Top 25 in Population Top 25 in GDP

USA, China, EU25, Russia, India, Japan, Germany, Brazil, UK, Italy, Mexico, France, Indonesia, Iran, Turkey

Ukraine, Pakistan

Canada, S.Korea, Australia, S.Africa, Spain, Poland, Argentina

Netherlands, (Taiwan)

Thailand

Bangladesh, Nigeria, Viet Nam, Philippines, Ethiopia, Egypt, Congo

WRI/Pew Center; data for 2000


22ndnd element: Common but differentiated element: Common but differentiated responsibilities and respective capabilitiesresponsibilities and respective capabilities

Qualitativenon-binding

Partialnot strict

Quantitativebinding

All-inclusivestrict

• Business As Usual • No-regret PAMs• Sustainable Development (eg

via CDM)• SD-PAMs• S-CDM• Non-binding target

(~> dual target) • Sectoral target• Relative emission ceiling• Absolute emission ceiling +

price ceiling

• Absolute emission ceilings

Lower Stage of

development

Higher Stage of

development

Possible indicators:

GNP per capita, CO2/Joule

CO2 per capita

Human Development Index

Relative importance of sectors


33rdrd element: Include more sectors element: Include more sectors

• aviation

• maritime transport

• deforestation


44thth element: Deploy and develop element: Deploy and develop technologies!technologies!

Subsidise new technologies Subsidise new technologies (e.g. guarantee demand, set (e.g. guarantee demand, set standards, large scale standards, large scale demos, public-private demos, public-private partnerships for technology partnerships for technology development, tax development, tax reductions)reductions)

Emissions trading Emissions trading Level playing field Level playing field

(abolition of fuel subsidies, (abolition of fuel subsidies, carbon taxes, feed in tariffs)carbon taxes, feed in tariffs)

Co-benefits (security of Co-benefits (security of supply, rising oil prices)supply, rising oil prices)

PUSH FACTORS PULL FACTORS


44thth element: Don’t miss near-term element: Don’t miss near-term opportunitiesopportunities

EU: Build and refurbish 700 GW of EU: Build and refurbish 700 GW of electricity generation by 2030 (equal electricity generation by 2030 (equal to current installed capacity).to current installed capacity).

China: 562 coal- fired plants -- nearly China: 562 coal- fired plants -- nearly half the world's total – by 2013half the world's total – by 2013

India: 213 coal-fired power plants by India: 213 coal-fired power plants by 20132013

United States is expected to build 72 United States is expected to build 72 until 2013until 2013

$ 16 trillion investment into the $ 16 trillion investment into the world’s energy systems until 2030world’s energy systems until 2030


44thth element: There is no silver bullet element: There is no silver bulletEm

issio

ns (

Gt

CO

2)


55thth element: element:Adapt to the adverse effects of climate changeAdapt to the adverse effects of climate change

• identify vulnerabilities identify vulnerabilities

• implement measures to implement measures to increase resilience increase resilience


No time to loose….No time to loose….Concrete steps:Concrete steps:

Immediate and effective implementation of Immediate and effective implementation of agreed policies (e.g. EU Energy Efficiency agreed policies (e.g. EU Energy Efficiency Initiative)Initiative)

Increased public awarenessIncreased public awareness More and better focussed researchMore and better focussed research Stronger co-operation with 3Stronger co-operation with 3rdrd countries countries New phase of the European Climate Change New phase of the European Climate Change

Programme in 2005 (review, cars, aviation, Programme in 2005 (review, cars, aviation, carbon capture and storage, adaptation)carbon capture and storage, adaptation)


The EU’s response toThe EU’s response toClimate ChangeClimate Change


Ratification on 31 May 2002 (Decision 2002/358/EC)Ratification on 31 May 2002 (Decision 2002/358/EC)The Bubble:The Bubble:

EU-15 Member State QELRC commitment(% reduction of base year/period emissions)

Austria -13

Belgium -7.5

Denmark -21

Finland 0

France 0

Germany -21

Greece +25

Ireland +13

Italy -6.5

Luxembourg -28

The Netherlands -6

Portugal +27

Spain +15

Sweden +4

United Kingdom -12.5

Total EU-15 Commitment: -8%


European Climate Change Programme European Climate Change Programme (ECCP): main elements(ECCP): main elements

ObjectivesObjectives Identify and develop cost effective elements of

EU strategy to meet our Kyoto target Major MilestonesMajor Milestones

Launch March 2000 May 2003 : second progress report New phase started on 24 October 2005 (review, aviation,

transport, adaptation and carbon capture and storage) Major AchievementsMajor Achievements

Total reduction potential of identified measures: 578 - 696 Mt CO2eq./year = twice Kyoto ‘-8%’

EU Measures currently “in implementation”: 276 - 316 Mt CO2eq./year


Domestic action:Domestic action:Recently adopted measuresRecently adopted measures

Cross-cutting issues• Directive on GHG emissions trading within the Community (Oct. 2003)• Linking project-based mechanisms to GHG emissions trading (Oct. 2004)• Decision for monitoring Community GHG emissions and for implementing the Kyoto Protocol (Feb. 2004)

Energy• Directive on the promotion of renewable energy sources (Sept. 2001) • Directive on taxation of energy products (Oct. 2003)• Directive on energy performance of buildings (Jan. 2003)• Directive on the promotion of cogeneration (CHP) (Feb. 2004)

Transport• Promotion of the use of bio-fuels for transport (May 2003)


Domestic action:Domestic action:Ongoing work….Ongoing work….

Energy• Proposal for a framework directive on eco-efficiency requirements

for energy-using products• Proposal for a Directive on energy end-use efficiency and energy

services• Commission Green Paper on energy efficiency or doing more with

less

Transport• Proposal for improvements in infrastructure use and charging • Proposal on special tax arrangements for diesel fuel used for

commercial purposes and on the alignment of excise duties on petrol and diesel fuel

• Proposal for a regulation on the granting of Community financial assistance to improve the environmental performance of the freight transport system (Marco Polo I and II program)

Products• Proposal for legislative action on fluorinated gases


Implementation challenge ahead:Implementation challenge ahead:The EU’s projected progressThe EU’s projected progress

90

95

100

105

110

1990

1995

2000

2005

2010

base

year em

issi

ons=

100

EU-25 emissions

EU-25 existing measures

EU-25 additionalmeasures

EU-15 emissions

EU-15 existing measures

EU-15 additionalmeasures

EU-15 target (Kyoto)

Business as usual

Linear target path

Kyoto mechanisms

Slide 3/96


Distance-to-target in 2010 (percentage points) Distance-to-target in 2010 (percentage points) for the EU-25, including Kyoto mechanismsfor the EU-25, including Kyoto mechanisms

-5

5

9

10

13

13

19

26

-12

0

12

-8

-6

-17

-49

0,9

1

0,1

-38

25

14

13

-43

-18

0

-18,5

0

-5

-13

-0,1

0

-0,4

-3

0

-3,5

-40,6

-2

3

8

156

0

-52

- 60 - 50 - 40 - 30 - 20 - 10 0 + 10 + 20 + 30 + 40

EU-25

EstoniaLithuania

LatviaLuxembourg

Czech RepublicSlovakia

United KingdomPoland

SwedenHungary

NetherlandsGermanyBelgium

FranceGreeceFinland

ItalyAustria

SloveniaIreland

DenmarkPortugal

Spain

Percentage points over-delivery (-) or shortfall (+) of respective emission target

With existing domestic measures With additional domestic measures

both including use of Kyoto mechanisms

Notes: Data exclude emissions and removals from land-use, land-use change and forestry. All EU-15 Member States provided projections assuming existing domestic policies and measures. Several countries provided projections with additional domestic policies and measures. For following Member States the

additional effects of the use of Kyoto mechanisms is included: Austria, Belgium, Denmark, Finland, Ireland, Italy, Luxembourg, the Netherlands and Spain),. For EU-15 the effect of use of Kyoto mechanisms is calculated based on information from these nine countries. Projections for Poland cover only CO2 and

N2O and include LULUCF. Projections for Spain cover only CO2. Projections for Cyprus and Malta are not available. Source: EEA, 2005


Use of Kyoto Mechanisms:Use of Kyoto Mechanisms:Planned purchases by Member StatesPlanned purchases by Member States

(in addition to company use!)(in addition to company use!)

Almost 520 Million tonnes of CO2eq (2008-2012)

Allocated resources thus far: 2.7 billion €

Million tonnes of CO2 eq.

Austria 35.00

Belgium 42.00

Denmark 22.50

Finland At least 3.0

Ireland 18.50

Italy 198.00

Luxembourg 15.00

Netherlands 100.00

Spain 100.00

Sweden At least 5.0


EU Emissions TradingEU Emissions Trading


Why emissions trading?Why emissions trading?

It is a modern environmental policy:It is a modern environmental policy: It rightly places a greater emphasis upon cost-

effectiveness and encouraging innovation The larger the cuts, the more difficult to stick to “old

style” regulation

The world is becoming a "global village" where The world is becoming a "global village" where companies compete internationally and are based companies compete internationally and are based themselves across different continentsthemselves across different continents Tackling a global environmental problem requires

environmental policies which work in conjunction with these international markets


Cap and TradeCap and Trade

Irrelevant where GHG are emitted!Irrelevant where GHG are emitted!

Set overall target covering group of sourcesSet overall target covering group of sources Allocate Allocate allowancesallowances Sources can choose:Sources can choose:

Emit as allocated Reduce emissions below allocation and sell or bank Emit more than allocation and buy


EU ETS: scheme coverageEU ETS: scheme coverage

COCO22 emissions from energy emissions from energy

intensive industry above specific intensive industry above specific capacity thresholds (45 – 50 % of capacity thresholds (45 – 50 % of EU COEU CO22 emissions) emissions)

11,500 or more installations 11,500 or more installations electricity generators heat & steam production mineral oil refineries ferrous metals: production

& processing cement, lime glass, bricks and

ceramics pulp & paper sector


Simple and transparent:Simple and transparent:Subsidiarity – important role for Member StatesBased on and linked to other Community legislation

(Integrated Pollution and Prevention Control – IPPC Directive) Starts with known large emitters, measurable

emissionsBuilding blocks – easy to expand

Lower costs & guaranteed environmental outcome

EU Greenhouse Gas Emissions Trading


Key InstrumentsKey Instruments

DirectiveDirective 2003/87/EC of the European Parliament and of the Council of 13 October 2003/87/EC of the European Parliament and of the Council of 13 October 2003 2003 establishing a scheme for greenhouse gas emission allowance trading within the establishing a scheme for greenhouse gas emission allowance trading within the CommunityCommunity and amending Council Directive 96/61/EC and amending Council Directive 96/61/EC[Emissions Trading Directive][Emissions Trading Directive]

DirectiveDirective 2004/101/EC of the European Parliament and of the Council of 27 October 2004/101/EC of the European Parliament and of the Council of 27 October 2004 amending Directive 2003/87/EC establishing a scheme for greenhouse gas 2004 amending Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community, emission allowance trading within the Community, in respect of the Kyoto Protocol's in respect of the Kyoto Protocol's project mechanismsproject mechanisms[Linking Directive, amending Emissions Trading Directive][Linking Directive, amending Emissions Trading Directive]

Commission Commission DecisionDecision of 29 January 2004 establishing of 29 January 2004 establishing guidelines for the monitoring guidelines for the monitoring and reporting of greenhouse gas emissionsand reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the pursuant to Directive 2003/87/EC of the European Parliament and of the CouncilEuropean Parliament and of the Council[Monitoring and Reporting Guidelines][Monitoring and Reporting Guidelines]

Commission Commission RegulationRegulation of 21 December 2004 for a of 21 December 2004 for a standardised and secured system of standardised and secured system of registriesregistries pursuant to Directive 2003/87/EC of the European Parliament and of the pursuant to Directive 2003/87/EC of the European Parliament and of the Council and Decision 280/2004/EC of the European Parliament and of the CouncilCouncil and Decision 280/2004/EC of the European Parliament and of the Council[Registries Regulation] [Registries Regulation]


Key TermsKey Terms

Activity (Annex I)Activity (Annex I) Installation (IPPC definition)Installation (IPPC definition)

Installation means a stationary technical unit where one or more activities listed in Annex I are carried out and any other directly associated activities which have a technical connection with the activities carried out on that site and which could have an effect on emissions and pollution

OperatorOperator Operator means any person who operates or controls and installation or,

where this is provided for in national legislation, to whom decisive economic power over the technical functioning of the installation has been delegated

Activities in Annex I leading to GHG emissions cannot be Activities in Annex I leading to GHG emissions cannot be undertaken unless the operator holds a undertaken unless the operator holds a permitpermit

The operator must hold sufficient The operator must hold sufficient allowancesallowances to cover GHG to cover GHG emissions from installation emissions from installation


2005 – 20072005 – 2007 2008 – 2012 & 2008 – 2012 & subsequent 5-year periodssubsequent 5-year periods Initially limited to COInitially limited to CO22 only only Large sources, mostly covered by IPPC (Annex I)Large sources, mostly covered by IPPC (Annex I)

(45% of EU CO2 emitting activities, around 11’500 installations)

Add in additional sectors/gases through:Add in additional sectors/gases through:Unilateral inclusion (below thresholds, new gases and

activities)amendments

Timing & Coverage


CoverageCoverage


AllocationAllocation

By Member States, but:By Member States, but: National Allocation Plan (NAP) (total allocation and

allocation methodology), draft by 31 March 2004 95% of allocation free of charge (90% after 2008) Guidelines for Allocation in Annex III Commission Allocation Guidance by 31 December 2003 (7

Jan 2004) – further guidance expected soon State aid provisions 3 month assessment of NAPs by Commission Allocation 3 months before start of trading period [Issue annually by 28 February]


The NAP decisions….The NAP decisions….

Last NAP approved on 20 June 2005 (Greece)Last NAP approved on 20 June 2005 (Greece)


Monitoring, Reporting:Monitoring, Reporting: Calculation, basic guidelines in Annex IV (Commission

Decision of 29 January 2004)

Verification:Verification: Basic guidelines in Annex V, Member States to decide

on role authorities/private verifiers (voluntary coord?)

Compliance:Compliance: Member State competence, harmonized penalty

(€40-100 + compensating for shortfall + “naming and shaming” )

Existing EU compliance framework(Member State implementation – penalties for failure to do so)

Monitoring, Verification, Compliance


The Registry SystemThe Registry System

Combined EU-UNFCCC registry systemCombined EU-UNFCCC registry system EU allowances, AAUs, CERs (+ lCERs, tCERs), ERUs, EU allowances, AAUs, CERs (+ lCERs, tCERs), ERUs,

RMUsRMUs

UNFCCC Independent Transaction LogUNFCCC Independent Transaction Log Community Independent Transaction LogCommunity Independent Transaction Log

http://europa.eu.int/comm/environment/ets/welcome.dohttp://europa.eu.int/comm/environment/ets/welcome.do

26 National Registries26 National RegistriesRegistries Regulation!Registries Regulation!

18 Registries online thus far (10 February 2006)18 Registries online thus far (10 February 2006)

http://europa.eu.int/comm/environment/ets/welcome.do


25 EU Member States25 EU Member States Future Member States (Bulgaria, Future Member States (Bulgaria,

Romania, Turkey, Croatia)Romania, Turkey, Croatia) EEA (Norway, Iceland, Liechtenstein)EEA (Norway, Iceland, Liechtenstein) Art 25: bilateral agreements with other Art 25: bilateral agreements with other

regimes:regimes: Switzerland, Canada, New Zealand,

Japan…..

Membership of the Trading SchemeMembership of the Trading Scheme


The Linking DirectiveThe Linking Directive

Direct use of JI and CDM credits by operators in Direct use of JI and CDM credits by operators in the EU ETS to achieve compliance with their the EU ETS to achieve compliance with their targets (1 CER or ERU = 1 EU Allowance)targets (1 CER or ERU = 1 EU Allowance)

CDM from 2005, JI from 2008CDM from 2005, JI from 2008 All project credits, except Nuclear energy All project credits, except Nuclear energy

projects (up to 2012) and LULUCF projects projects (up to 2012) and LULUCF projects (review in mid-2006(review in mid-2006

From 2008 use limited to % of allocation of From 2008 use limited to % of allocation of allowances to each installationallowances to each installation

Th

e re

su

lt….

Th

e re

su

lt….


Source

: Poin

t Carb

on's C

arb

on M

arke

t D

aily

Carbon prices & traded volumes

3 February 2006EUA 2005 spot

(€/tCO2) €27.18

2005 total volume: 260 million allowances approx.

2005 market valuation: €5.4 billion

Volume of EU allowances traded (monthly and cumulative), 2005

0

50,000,000

100,000,000

150,000,000

200,000,000

250,000,000

300,000,000

Dec-04

Jan-05

Feb-05

Mar-05

Apr-05

May-05

Jun-05

Jul-05

Aug-05

Sep-05

Oct-05

Nov-05

Dec-05

Month

Monthly

Cumulative


Facts and figuresFacts and figures

Close to 6.6 billion allowances will be allocated in 2005-2007

Total asset value over € 140 billion 1-3 million allowances traded daily 14 national registries online, all expected to

be operational by the end of 2005


The next steps…..The next steps…..

Commission issued additional allocation guidance Commission issued additional allocation guidance on 22 December 2005on 22 December 2005

Compliance:Compliance: Submission of verified emissions report by 31 March

annually Surrender of allowances by 30 April annually

New NAPs by 30 June 2006New NAPs by 30 June 2006

Commission Communication of 27 September 2005 Commission Communication of 27 September 2005 “Reducing the Climate Change Impact of Aviation” “Reducing the Climate Change Impact of Aviation” (COM(2005) 459)(COM(2005) 459)

Review of ETS by 30 June 2006Review of ETS by 30 June 2006


What the review is about

Improve the functioning of the scheme based on practical implementation experience

Streamline current scheme … More predictable allocation rules through

stable baseline years and/orlonger allocation period and/orderive future allocation from past allocation

More harmonised approach to new entrants and closures, based on experience during 2005-07 period

Further harmonisation in the area of verification …and expand to other sectors and gases, beyond

aviation


Main results of the EU ETS stakeholder survey (McKinsey and Ecofys, 2nd half 2005)

EU ETS has an impact on corporate behaviour – all EU ETS has an impact on corporate behaviour – all sectors price in value of allowancessectors price in value of allowances

Long-term topics have highest priority for all stakeholdersLong-term topics have highest priority for all stakeholders However no clear consensus – harmonise allocation, but However no clear consensus – harmonise allocation, but

how?how? Companies vote for longer allocation periods (ten years or more) Benchmarking seen as interesting alternative, however most companies

think more than 3 benchmarks per sector are needed More auctioning disliked by companies but favoured by other

stakeholders

Wide consensus that scheme design changes should be Wide consensus that scheme design changes should be brought in with sufficient lead-timebrought in with sufficient lead-time


Action on Climate Change Action on Climate Change “post-2012”“post-2012”


COP President Stéphane Dion’s Three “I”sCOP President Stéphane Dion’s Three “I”sResults of Montreal Results of Montreal (December 2005)(December 2005)

Implement:Implement:Adopt the “Marrakech Accords”Adopt the compliance regime

ImproveImproveStrengthen the Clean Development Mechanism

InnovateInnovateStart a dialogue on future action to tackle climate

change both under the Convention and the Protocol


The results: ImplementationThe results: Implementation

Adoption of the Marrakech Accords:Adoption of the Marrakech Accords: the rulebook for the rulebook for the Kyoto Protocol adopted in full on Wednesday of the the Kyoto Protocol adopted in full on Wednesday of the first week.first week.

Adoption of the Compliance DecisionAdoption of the Compliance Decision: discussions on the : discussions on the Saudi proposal to amend the Kyoto Protocol started to Saudi proposal to amend the Kyoto Protocol started to be finalised by COP/MOP-3.be finalised by COP/MOP-3.

Five-year adaptation work programmeFive-year adaptation work programme: agreed full set of : agreed full set of activities, including work to further enhance our activities, including work to further enhance our knowledge on the impacts of and vulnerabilities to knowledge on the impacts of and vulnerabilities to climate change and contains concrete measures to plan climate change and contains concrete measures to plan for adaptation and take adaptation measures.for adaptation and take adaptation measures.

Adaptation FundAdaptation Fund: details on the Fund’s management : details on the Fund’s management will be elaborated during 2006will be elaborated during 2006


The results: ImprovementThe results: Improvement

Strengthening the Clean Development Mechanism (CDM)Strengthening the Clean Development Mechanism (CDM): : clarification and strengthening of theclarification and strengthening of the CDM Executive Board’s CDM Executive Board’s executive and supervisory role. Parties pledged US$ 8,188,050 executive and supervisory role. Parties pledged US$ 8,188,050 to the operation of the CDM (US$ 5 million from the EU, and to the operation of the CDM (US$ 5 million from the EU, and US$ 890,000 from the Commission).US$ 890,000 from the Commission).

Carbon Capture and Storage (CCS)Carbon Capture and Storage (CCS): presentation special : presentation special report on CCS by Intergovernmental Panel on Climate report on CCS by Intergovernmental Panel on Climate Change (IPCC). Follow-up workshops in May to disseminate Change (IPCC). Follow-up workshops in May to disseminate its results and to consider role of CCS under the CDM. The its results and to consider role of CCS under the CDM. The inclusion of CCS in the CDM will be further considered at the inclusion of CCS in the CDM will be further considered at the next COP/MOP.next COP/MOP.

Kick-starting Joint Implementation (JI)Kick-starting Joint Implementation (JI): JI institutions set up. : JI institutions set up. Preparatory work done for the CDM can also be used for the Preparatory work done for the CDM can also be used for the approval of JI projects. EU pledged over US$ 700,000 (incl. approval of JI projects. EU pledged over US$ 700,000 (incl. US$ 250,000 from the Commission) to the JI Supervisory US$ 250,000 from the Commission) to the JI Supervisory Committee, Canada pledged US$ 500,000.Committee, Canada pledged US$ 500,000.


The results: InnovationThe results: Innovation

The Convention Track:The Convention Track: forward-looking forward-looking dialogue under the Convention, up to four dialogue under the Convention, up to four Workshops over the next two years, results Workshops over the next two years, results reported back to the COP.reported back to the COP.

The Kyoto Track:The Kyoto Track: ad-hoc working group under ad-hoc working group under the Kyoto Protocol, will complete its work as the Kyoto Protocol, will complete its work as early as possible and in time to ensure that there early as possible and in time to ensure that there is no gap between the first and the second Kyoto is no gap between the first and the second Kyoto commitment period, next year’s full review of commitment period, next year’s full review of the Kyoto Protocol prepared with submissions of the Kyoto Protocol prepared with submissions of views in September.views in September.


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