Thank you chair,

I’m Anja Kollmuss and would like these comments on behalf of Carbon Market Watch

The future of the Joint Implementation has to be put in context. The window of opportunity to prevent catastrophic climate change is rapidly closing.

Non-additional JI projects undermine mitigation goals, especially when they are implemented in countries with a large AAU surplus.

A large supply of non-additional ERUs does not only hamper climate goals but also severely undermine carbon markets.

The recommendations by the JISC do not go far enough in terms of ensuring environmental integrity.  Our recommendations include, inter alia that

• Host Party eligibility should depend on ambitious QELRO to avoid hot air laundering through JI
• International oversight should be strengthened, especially at the registration stage.
• Criteria and review Procedures for Baseline setting must be strengthened
• As well as additionality requirements
• Rules should be implemented that require that all existing projects have to go through a procedure for renewal of their crediting period that includes a review of their baseline scenario.