Dear Mr. Seidel, Members and Alternate Members of the JI Supervisory Committee,

We appreciate having the opportunity to provide input on the Draft Joint Implementation Mechanism (JI) Guidelines. We hope that our suggestions will contribute to the reform of the JI in a way that will ensure that JI will be a mechanism capable of delivering real, measurable and additional GHG emission reductions. Below we present our views on how the proposed Draft JI Guidelines can be further developed in order to improve the mechanism.

First we must put the future of the JI in context. The window of opportunity to prevent catastrophic climate change is rapidly closing. Several studies show that current pledges are woefully insufficient to keep warming below 2oC. Furthermore, they show that loopholes such as the surplus allowances (AAUs) from the first Kyoto commitment period (commonly referred to as ‘hot air’) could negate all current pledges and enable developed countries to meet mitigation targets while continuing with business-as-usual levels of emissions.1 We are now on an emissions path that could lead to warming of 4oC or more.2 In addition, impacts associated with even 2oC of warming have been revised upwards and are now considered “dangerous” and “extremely dangerous”.3 Maintaining a reasonable likelihood of limiting temperature increases to within 2°C will require much higher levels of ambition by all nations.

The insufficient current ambition levels also have led to a severe price decay in the carbon markets. At current price ranges, it is all but impossible to implement JI projects that are truly additional. Non-additional JI projects undermine mitigation goals, especially when they are implemented in countries with a large AAU surplus. A large supply of such ERUs will not only hamper climate goals but also severely undermine carbon markets.