To: Mr. Oleh Dubyna
Chairman of the Inter-Ministerial
Commission on Climate Change

Kyiv, October 23, 2001

Proposals of the NGO Working Group regarding Ukraine’s position at the Seventh Conference of Parties to the UN Framework Convention on Climate Change

The Ukrainian NGO Climate Change Working Group welcomes the political agreement reached at the Conference of Parties in Bonn. This agreement holds out a hope that countries will start concrete activities to reduce greenhouse gases emissions. We consider that the results of the Bonn conference were especially important in the situation when the US position was undermining the agreement, and we hope that now the Bush administration will give a thorough consideration of the future of our planet and support the agreement. We applaud the decision to exclude nuclear power projects from the Protocol mechanisms.

However, on the eve of the Seventh Conference of Parties we do not regard the Bonn agreement as sufficient. Big quotas permitting developed countries to use sinks, unlimited possibility to trade emission allowances and lack of agreement on liability could allow developed countries to meet their obligations without substantial emission reductions.

National-level actions are becoming more and more important. The Government of Ukraine should ratify the Kyoto Protocol and start active restructuring of the economy to raise its efficiency. We regard that Ukraine should pursue the policy that would help to block loopholes to fulfil international obligations by developed countries for the sake of preserving the climate on our planet.

Up to date Ukraine has no clear strategy on global climate change mitigation, therefore, we expect the following actions from the Ukrainian authorities:

1. To ratify the Kyoto Protocol.
2. To intensify the work on development of the national environmental policy of Ukraine in the context of climate change, namely:
• to develop an action plan that would contain principles, strategy, measures and financial arrangements for climate change mitigation activities. Implementation of this action plan would be extremely useful both for the environment and the economy of Ukraine;
• to coordinate action plans of major national economy development programs with the goals of the Convention and the Protocol;
• to raise the priority of the least cost greenhouse gases reducing projects and implement them at the expense of internal resources. This would increase the probability of receiving investments where they are really needed;
• to define a list of types of projects eligible for implementation within the framework of the joint implementation (JI) mechanism and relevant criteria of eligibility;
• to establish an official structure for management, coordination and control of JI projects. The activities of this structure should be transparent and accessible to public control;
• to refrain from “hot air” trading and reserve related allowances for the next commitment periods. It can be predicted that economic growth will make it difficult for Ukraine to meet its obligations through real emissions reductions and then “hot air” could be used for “internal use”;
• to apply diplomatic agreements with Russia about a minimum price for allowances under the mechanism of emission trading. Ukraine should take the opportunity to obtain modern technologies under the JI mechanism. Too low price for allowances under the emission trading would lead to reallocation of investments that could be spent on JI projects.
3. To develop clear mechanisms for public access to information and participation in implementation of the flexible mechanisms of the Kyoto Protocol. Public involvement will ensure the most effective implementation and at the same time monitoring of any particular project.

We believe that the Ukrainian official delegation at the Conference of Parties in Marrakech will be working to nail and develop agreements reached in Bonn. We are particularly concerned about loopholes that still remain in the Protocol mechanisms. We would appreciate any provisions regarding public control over implementation of the Protocol. We believe that the best demonstration of the state interest to involve the public in the process would be including a representative of our Working Group to the official delegation.

In our view the following issues require special attention in Marrakech:

1. There should be strict rules on control and monitoring of sinks-related projects within the first commitment period. The Working Group would recommend the Government to insist on exclusion of sinks-related projects from the framework of flexible mechanisms starting from the second commitment period, if the projects of the first period would not result in the planned emission reductions.
2. The term “refrain”, applied in the Bonn agreement with regard to nuclear power should be better interpreted in the final text. Nuclear power should be excluded from the mechanisms of the Kyoto Protocol!
3. Flexible mechanisms would not work well without a system of liability. Ukraine should stand for introduction of such a system, otherwise the Protocol would not work properly.

Ukrainian NGO Climate Change Working Group:
tel./fax: +380 (44) 246-4799,
e-mail:climNGOukr@yahoogroups.com