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entitled 'Climate Change: The Quality, Comparability, and Review of 
Emissions Inventories Vary Between Developed and Developing Nations' 
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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

July 2010: 

Climate Change: 

The Quality, Comparability, and Review of Emissions Inventories Vary 
Between Developed and Developing Nations: 

GAO-10-818: 

GAO Highlights: 

Highlights of GAO-10-818, a report to congressional requesters. 

Why GAO Did This Study: 

Nations that are Parties to the United Nations Framework Convention on 
Climate Change periodically submit inventories estimating their 
greenhouse gas emissions. The Convention Secretariat runs a review 
process to evaluate inventories from 41 “Annex I” nations, which are 
mostly economically developed nations. The 153 “non-Annex I” nations 
are generally less economically developed and have less stringent 
inventory reporting guidelines. The Department of State (State) 
represents the United States in international climate change 
negotiations. GAO was asked to report on (1) what is known about the 
comparability and quality of inventories and barriers, if any, to 
improvement; (2) what is known about the strengths and limits of the 
inventory review process; and (3) views of experts on implications for 
current and future international agreements to reduce emissions. GAO 
analyzed inventory reviews and inventories from the seven highest-
emitting Annex I nations and seven of the highest emitting non-Annex I 
nations. GAO also selected and interviewed experts. 

What GAO Found: 

Recent reviews by expert teams convened by the Secretariat found that 
the 2009 inventories from the selected Annex I nations—Australia, 
Canada, Germany, Japan, Russia, the United Kingdom, and the United 
States—were generally comparable and of high quality. For selected non-
Annex I nations—Brazil, China, India, Indonesia, Malaysia, Mexico, and 
South Korea—GAO found most inventories were dated and of lower 
comparability and quality. Experts GAO interviewed said data 
availability, scientific uncertainties, limited incentives, and 
different guidelines for non-Annex I nations were barriers to 
improving their inventories. The lack of comparable, high quality 
inventories from non-Annex I nations is important because they are the 
largest and fastest growing source of emissions, as shown in the 
figure, and information about their emissions is important to efforts 
to address climate change. There are no inventory reviews for non-
Annex I nations. 

Figure: Energy-Related Carbon Dioxide Emissions in Annex I and Non-
Annex I Nations, 1992-2030: 

[Refer to PDF for image: multiple line graph] 

Metric tons in billions: 

Actual: 

Year: 1992; 
Annex I: 13.9; 
Non-Annex I: 7.6. 

Year: 1993; 
Annex I: 13.8; 
Non-Annex I: 7.9. 

Year: 1994; 
Annex I: 13.6; 
Non-Annex I: 8.3. 

Year: 1995; 
Annex I: 13.7; 
Non-Annex I: 8.5. 

Year: 1996; 
Annex I: 13.9; 
Non-Annex I: 8.8. 

Year: 1997; 
Annex I: 14.0; 
Non-Annex I: 9.2. 

Year: 1998; 
Annex I: 13.9; 
Non-Annex I: 9.2. 

Year: 1999; 
Annex I: 14.1; 
Non-Annex I: 9.3. 

Year: 2000; 
Annex I: 14.4; 
Non-Annex I: 9.5. 

Year: 2001; 
Annex I: 14.3; 
Non-Annex I: 9.7. 

Year: 2002; 
Annex I: 14.4; 
Non-Annex I: 10.4. 

Year: 2003; 
Annex I: 14.7; 
Non-Annex I: 11.2. 

Year: 2004; 
Annex I: 14.9; 
Non-Annex I: 12.7. 

Year: 2005; 
Annex I: 15.0; 
Non-Annex I: 13.5. 

Year: 2006; 
Annex I: 15.0; 
Non-Annex I: 14.1. 

Year: 2007; 
Annex I: 15.0; 
Non-Annex I: 14.8. 

Year: 2008; 
Annex I: 14.9; 
Non-Annex I: 15.5. 

Year: 2009; 
Annex I: 14.8; 
Non-Annex I: 15.8. 

Projected: 

Year: 2010; 
Annex I: 14.7; 
Non-Annex I: 16.0. 

Year: 2011; 
Annex I: 14.6; 
Non-Annex I: 16.2. 

Year: 2012; 
Annex I: 14.6; 
Non-Annex I: 16.5. 

Year: 2013; 
Annex I: 14.5; 
Non-Annex I: 16.7. 

Year: 2014; 
Annex I: 14.4; 
Non-Annex I: 16.9. 

Year: 2015; 
Annex I: 14.3; 
Non-Annex I: 17.2. 

Year: 2016; 
Annex I: 14.4; 
Non-Annex I: 17.6. 

Year: 2017; 
Annex I: 14.4; 
Non-Annex I: 18.1. 

Year: 2018; 
Annex I: 14.4; 
Non-Annex I: 18.5. 

Year: 2019; 
Annex I: 14.4; 
Non-Annex I: 18.9. 

Year: 2020; 
Annex I: 14.4; 
Non-Annex I: 19.4. 

Year: 2021; 
Annex I: 14.5; 
Non-Annex I: 19.9. 

Year: 2022; 
Annex I: 14.5; 
Non-Annex I: 20.4. 

Year: 2023; 
Annex I: 14.6; 
Non-Annex I: 20.8. 

Year: 2024; 
Annex I: 14.6; 
Non-Annex I: 21.3. 

Year: 2025; 
Annex I: 14.6; 
Non-Annex I: 21.8. 

Year: 2026; 
Annex I: 14.7; 
Non-Annex I: 22.3. 

Year: 2027; 
Annex I: 14.8; 
Non-Annex I: 22.8. 

Year: 2028; 
Annex I: 14.8; 
Non-Annex I: 23.3. 

Year: 2029; 
Annex I: 14.9; 
Non-Annex I: 23.8. 

Year: 2030; 
Annex I: 14.9; 
Non-Annex I: 24.4. 

Source: GAO analysis of Energy Information Administration data. 

[End of figure] 

Experts said the inventory review process has notable strengths for 
Annex I nations as well as some limitations. The review process, which 
aims to ensure nations have accurate information on inventories, is 
rigorous, involves well-qualified reviewers, and provides feedback to 
improve inventories, according to experts. Among the limitations 
experts identified is a lack of independent verification of estimates 
due to the limited availability of independent statistics against 
which to compare inventories’ data. Also, GAO found that the review 
process’s quality assurance framework does not independently assess 
concerns about a limited supply of reviewers and inconsistent reviews, 
which could pose challenges in the future. Experts said Annex I nations’
 inventories and the inventory review process are generally sufficient 
for monitoring compliance with current agreements to reduce emissions. 
For non-Annex I nations, however, experts said the current system may 
be insufficient for monitoring compliance with future agreements, 
which may require more reporting. As part of ongoing negotiations to 
develop a new climate change agreement, State has emphasized the need 
for better information on emissions from high-emitting non-Annex I 
nations. While improving the inventory system is important to 
negotiations, some experts said disagreements about emissions limits 
for developed and developing nations pose a greater challenge. 

What GAO Recommends: 

GAO recommends that the Secretary of State work with other Parties to 
the Convention to (1) continue encouraging non-Annex I Parties to 
improve their inventories and (2) strengthen the inventory review 
process’s quality assurance framework. State agreed with GAO’s 
findings and recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-10-818] or key 
components. For more information, contact John Stephenson at (202) 512-
3841 or stephensonj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Inventories From Seven Annex I Nations Were of Higher Comparability 
and Quality than Those From Seven Non-Annex I Nations Because of 
Several Barriers: 

The Inventory Review Process for Annex I Nations Has Several Strengths 
and Some Limitations, and No Comparable Process Exists for Non-Annex I 
Nations: 

Experts Said the Inventory System Is Generally Sufficient for 
Monitoring Compliance with Current Agreements, but Future Agreements 
with Non-Annex I Nations Could Pose Challenges: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Third-Party Views: 

Appendix I: Scope and Methodology: 

Appendix II: List of Experts: 

Appendix III: Comments from the Department of State: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Estimates of Uncertainty Reported in Seven Annex I Nations' 
2009 Inventories for Emissions in 2007: 

Table 2: Greenhouse Gas Emissions and Uncertainty for Selected 
Categories from the 2009 U.S. Inventory for Emissions in 2007: 

Table 3: Select Actions Submitted Under the Copenhagen Accord and 
Potential Challenges Identified by Experts: 

Figures: 

Figure 1: Global Greenhouse Gas Emissions by Gas and by Economic 
Sector, 2005: 

Figure 2: Size and Structure of Greenhouse Gas Emissions and Per-
Capita Income for 14 Selected Nations, 2005: 

Figure 3: Inventory Submissions from Annex I Parties, 1998-2010: 

Figure 4: Comparison of Most Recent Greenhouse Gas Emissions 
Inventories Submitted by Selected Annex I and Non-Annex I Nations: 

Figure 5: Energy-Related Carbon Dioxide Emissions in Annex I and Non- 
Annex I Nations, 1992 through 2030, Actual and Projected: 

Figure 6: Review Process for Inventories from Annex I Nations: 

Abbreviations: 

EPA: Environmental Protection Agency: 

IEA: International Energy Agency: 

IPCC: Intergovernmental Panel on Climate Change: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

July 30, 2010: 

The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Michael C. Burgess:
Ranking Member:
Subcommittee on Oversight and Investigations:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Greg Walden:
House of Representatives: 

High-quality information on greenhouse gas emissions is critical to 
domestic and international efforts to address climate change. Elevated 
concentrations of greenhouse gases in the atmosphere could alter the 
climate and adversely affect agriculture, infrastructure, ecosystems, 
and human health. To address these risks, Congress is considering 
proposals to limit greenhouse gas emissions, and the United States is 
participating in international negotiations to develop an 
international response to climate change. 

In 1992, the United States and most nations of the world negotiated 
the United Nations Framework Convention on Climate Change (the 
Convention) to stabilize atmospheric concentrations of carbon dioxide 
and five other greenhouse gases.[Footnote 1] As a step toward that 
goal, under the 1997 Kyoto Protocol to the Convention, 37 
industrialized nations and the European Community agreed to binding 
emissions targets for 2008 through 2012.[Footnote 2] Many nations with 
significant greenhouse gas emissions, including China, India, and the 
United States, have not committed to such binding targets in the Kyoto 
Protocol or subsequently.[Footnote 3] However, all nations that are 
Parties to the Convention agreed, among other things, to periodically 
provide inventories detailing their man-made emissions and removals of 
greenhouse gases.[Footnote 4] These inventories, and processes for 
their review, play an important role in ongoing negotiations for a 
post-2012 agreement to extend or succeed the Kyoto Protocol. In 
December 2009, these negotiations resulted in the Copenhagen Accord, a 
nonbinding political agreement in which, among other things, certain 
nations announced various actions to reduce emissions and developing 
nations agreed to submit more frequent reports on their emissions. 

Forty-one of the Convention's Parties--most of them economically 
developed nations--are listed in Annex I of the Convention and submit 
annual inventories of their greenhouse gas emissions.[Footnote 5] 
Developing an inventory involves collecting data on activities across 
all sectors of a nation's economy that influence emissions and using 
numerous methods to estimate associated emissions. Annex I nations' 
inventories undergo a review process coordinated by the Convention's 
Secretariat, with reviews by teams of international experts. The 
review teams evaluate consistency with inventory guidelines agreed to 
by all Parties, including technical methods developed by the 
Intergovernmental Panel on Climate Change (IPCC).[Footnote 6] An 
additional 153 Parties to the Convention are not listed in Annex I and 
are known as non-Annex I nations. They are generally less economically 
developed, though strong economic growth since 1992 in some nations 
means their per-capita income now surpasses that of some Annex I 
nations. They are encouraged to use the same technical methods as 
Annex I nations in developing their inventories. However, the Parties 
agreed that inventories from non-Annex I nations do not need to be 
submitted as often, include estimates for as many gases, or undergo 
the same reviews as inventories from Annex I nations. In 2003, we 
reported that select Annex I nations varied in their adherence to 
reporting standards and that there was little information on 
inventories from select non-Annex I nations.[Footnote 7] 

The role of certain non-Annex I nations has become central to 
negotiations on a post-2012 agreement because their emissions have 
increased substantially since 1997 and are expected to continue to 
grow. China, a non-Annex I nation, recently overtook the United States 
as the world's largest emitter, according to some estimates.[Footnote 
8] According to Energy Information Administration projections, non- 
Annex I nations may contribute nearly all of the growth of global 
fossil-fuel related emissions through 2030.[Footnote 9] Because of 
this expected growth, emissions reductions will be needed from high-
emitting nations, including non-Annex I nations, to stabilize the 
concentration of greenhouse gases in the atmosphere. Recognizing this, 
the United States' position in international negotiations has been 
that a new climate change agreement should extend binding actions and 
strong requirements for monitoring, reporting, and verification of 
emissions to large non-Annex I nations. In negotiations, many non-
Annex I nations have taken the position that Annex I nations are 
obliged to begin to cut their emissions more deeply because they have 
emitted a large share of the greenhouse gases that currently drive 
climate change. 

In the United States, the Environmental Protection Agency (EPA) 
prepares the annual inventory with contributions from other agencies, 
including the Departments of Agriculture and Energy.[Footnote 10] The 
Department of State (State) represents the United States in 
international negotiations to develop a post-2012 agreement to address 
climate change, and participates in the assessment and review of 
whether the Convention is being effectively implemented, including the 
inventory review process. State also officially submits the U.S. 
inventory to the Convention's Secretariat. 

In response to your request, this report addresses the following 
questions: (1) what is known about the comparability and quality of 
inventories submitted by developed and developing nations and 
barriers, if any, to improving comparability and quality; (2) what is 
known about the strengths and limits of the Convention's inventory 
review process; and (3) what are the views of experts of the 
implications of the state of the inventory system for establishing or 
monitoring compliance with international agreements to reduce 
greenhouse gas emissions. 

To provide information on the comparability and quality of 
inventories, we summarized the results of the most recent inventory 
reviews of the seven largest emitting Annex I nations--Australia, 
Canada, Germany, Japan, Russia, the United Kingdom, and the United 
States. For non-Annex I nations, we assessed whether inventories from 
seven of the largest greenhouse gas emitting nations--Brazil, China, 
India, Indonesia, Malaysia, Mexico, and South Korea--included 
estimates for all major greenhouse gases, for all economic sectors, 
and for various years, among other factors. In 2005, the latest year 
for which global estimates are available, these 14 nations represented 
about two-thirds of the greenhouse gas emissions that were not related 
to land use and forestry.[Footnote 11] We did not independently assess 
the comparability or quality of inventories from Annex I nations or of 
emissions estimates from non-Annex I nations. Though we identified 
some limitations with the inventory review process, we believe that 
the reviews provide reasonable assessments of the comparability and 
quality of inventories from the selected Annex I nations. Our findings 
are not generalizable to other nations because the selected nations 
are not necessarily representative. To address all three objectives, 
we also summarized findings in the literature and the results of semi- 
structured interviews with 15 experts on national emissions 
inventories, the Convention's inventory review process, and 
international agreements. We selected these experts based on 
recommendations from U.S. and international government officials and 
researchers, the relevance and extent of their publications, and their 
involvement in the Convention's inventory review process and related 
activities. We ensured that our group of experts covered key 
perspectives, including the views of Annex I and non-Annex I nations 
and the views of experts not directly involved in preparing or 
reviewing inventories. Experts included agency and international 
officials, researchers, and members of inventory review teams. Not all 
of the experts provided their views on all issues. We identify the 
number of experts providing views where relevant. Appendix I provides 
additional information about our scope and methodology, and appendix 
II lists the experts we interviewed. 

We conducted this performance audit from September 2009 to July 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Greenhouse gases can affect the climate by trapping energy from the 
sun that would otherwise escape the earth's atmosphere. Various human 
and natural activities emit greenhouse gases, with the production and 
burning of fossil fuels for energy contributing around two-thirds of 
man-made global emissions in 2005 (see figure 1). The remaining third 
includes emissions from industrial processes, such as steel production 
and semiconductor manufacturing; agriculture, including emissions from 
the application of fertilizers and from ruminant farm animals; land 
use, such as deforestation and afforestation; and waste, such as 
methane emitted from landfills. Carbon dioxide is the most important 
of the greenhouse gases affected by human activity, accounting for 
about three-quarters of global emissions in 2005, the most recent year 
for which data were available.[Footnote 12] 

Figure 1: Global Greenhouse Gas Emissions by Gas and by Economic 
Sector, 2005: 

[Refer to PDF for image: 2 pie-charts] 

Emissions by Greenhouse Gas (percent)[A]: 
Synthetic gases[B]: 1%; 
Nitrous oxide: 8%; 
Methane: 15%; 
Carbon dioxide (other)[C]: 15%; 
Carbon dioxide from energy: 61%; 

Emissions by Economic Sector (percent): 
Waste: 3%; 
Industrial processes: 4%; 
Land-use change and forestry: 12%; 
Agriculture: 14%; 
Energy: 66%. 

Source: GAO analysis of World Resources Institute data. 

[A] Emissions are weighted by the 100-year global warming potential 
for each gas. 

[B] Synthetic gases include hydrofluorocarbons, perfluorocarbons, and 
sulfur hexafluoride. 

[C] Other includes carbon dioxide emissions from industrial processes, 
agriculture, land-use change and forestry, and waste. 

Note: Figure includes emissions and removals of greenhouse gases. 

[End of figure] 

The 14 nations in our study differ greatly in the quantity of their 
greenhouse gas emissions, the sources of those emissions, and their 
per-capita incomes. Emissions in 2005 ranged from about 7 billion 
metric tons of carbon dioxide equivalent in China and 6 billion metric 
tons in the United States, to about 300 million metric tons in 
Malaysia. The contribution of various sectors to national emissions 
also differed across nations, with emissions from energy and 
industrial processes accounting for more than 70 percent of emissions 
in most industrialized nations and 20 percent or less of emissions in 
Indonesia and Brazil (see figure 2). 

Figure 2: Size and Structure of Greenhouse Gas Emissions and Per-
Capita Income for 14 Selected Nations, 2005: 

[Refer to PDF for image: plotted point graph] 

Nation: United States; 
Per Cap income: $42,390; 
Ratio of emissions from energy and industrial processes to total 
emissions: 1.09. 

Nation: China; 
Per Cap income: $4,100; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.83. 

Nation: Indonesia; 
Per Cap income: $2,840; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.20. 

Nation: Brazil; 
Per Cap income: $8,300; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.13. 

Nation: Russian Federation; 
Per Cap income: $11,570; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.96. 

Nation: India; 
Per Cap income: $2,220; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.72. 

Nation: Japan; 
Per Cap income: $31,030; 
Ratio of emissions from energy and industrial processes to total 
emissions: 1.03. 

Nation: Germany; 
Per Cap income: $31,760; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.99. 

Nation: Malaysia; 
Per Cap income: $11,220; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.53. 

Nation: Australia; 
Per Cap income: $32,840; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.71. 

Nation: Canada; 
Per Cap income: $34,380; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.84. 

Nation: Mexico; 
Per Cap income: $12,360; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.76. 

Nation: United Kingdom; 
Per Cap income: $33,240; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.90. 

Nation: South Korea; 
Per Cap income: $22,760; 
Ratio of emissions from energy and industrial processes to total 
emissions: 0.94. 

Source: GAO analysis of World Resources Institute (non-Annex I 
nations), Convention (Annex I nations), and World Bank data. 

Notes: Size of circle represents total emissions from each nation. 
Since total emissions include emissions minus removals of greenhouse 
gases, energy and industrial process emissions are greater than total 
for some nations. Per capita income figures are converted from local 
currencies using purchasing power parities, which take into account 
differences in the relative prices of goods and services across 
nations. 

[End of figure] 

The Convention established a Secretariat that, among other things, 
supports negotiations, coordinates technical reviews of reports and 
inventories, and compiles greenhouse gas inventory data submitted by 
nations. The Secretariat has about 400 staff, located in Bonn, 
Germany, and its efforts related to national inventories are funded by 
contributions from the Parties.[Footnote 13] For the Secretariat's 
core budget, Parties provided $52 million for the 2008-2009 budget 
cycle, of which the United States contributed $9.5 million ($3.76 
million in 2008 and $5.75 million in 2009), excluding fees. 

The Convention requires Parties to periodically report to the 
Secretariat on their emissions of greenhouse gases resulting from 
human activities.[Footnote 14] Parties do not generally measure their 
emissions, because doing so is not generally feasible or cost 
effective, and instead estimate their emissions. To help Parties 
develop estimates, the IPCC developed detailed guidelines--which have 
evolved over time--describing how to estimate emissions. The general 
approach is to use statistics on activities, known as activity data, 
and estimates of the rate of emissions per unit of activity, called 
emissions factors.[Footnote 15] For example, to estimate emissions 
from passenger cars, the inventory preparers could multiply the number 
of gallons of gasoline consumed by all cars by the estimated quantity 
of emissions per gallon. The IPCC guidelines allow nations to use 
various methods depending on their data and expertise. In some cases, 
with adequate data, estimates of emissions can be as accurate as 
direct measurements, for example for carbon dioxide emissions from the 
combustion of fossil fuels which contribute the largest portion of 
emissions for many nations.[Footnote 16] 

The Parties agreed to the following five principles for inventories 
from Annex I nations: 

* Transparent. Assumptions and methodologies should be clearly 
explained to facilitate replication and assessment of the inventory. 

* Consistent. All elements should be internally consistent with 
inventories of other years. Inventories are considered consistent if a 
Party uses the same methodologies and data sets across all years. 

* Comparable. Estimates should be comparable among Parties and use 
accepted methodologies and formats, including allocating emissions to 
the six economic sectors defined by IPCC--energy, industrial 
processes, solvent and other product use, agriculture, land-use change 
and forestry, and waste. 

* Complete. Inventories should cover all sources and sinks and all 
gases included in the guidelines. 

* Accurate. Estimates should not systematically over-or underestimate 
true emissions as far as can be judged and should reduce uncertainties 
as far as practical.[Footnote 17] 

Annex I nations are to submit inventories annually consisting of two 
components--inventory data in a common reporting format and a national 
inventory report--both of which are publicly available on a Web site 
maintained by the Secretariat.[Footnote 18] The common reporting 
format calls for emissions estimates and the underlying activity data 
and emissions factors for each of six sectors--energy, industrial 
processes, solvent and other product use, agriculture, land-use change 
and forestry, and waste. It also calls for data on the major sources 
that contribute to emissions in each sector. The inventory data are to 
reflect a nation's most recent reporting year as well as all previous 
years back to the base year, generally 1990.[Footnote 19] The 2010 
reporting format called for nearly 150,000 items of inventory data and 
other information from 1990 through 2008. The common format and 
underlying detail facilitate comparisons across nations and make it 
easier to review the data by, for example, enabling automated checks 
to ensure emissions were properly calculated and to flag 
inconsistencies in data reported over time. 

The national inventory report should explain the development of the 
estimates and data in the common reporting format and should enable 
reviewers to understand and evaluate the inventory. The report should 
include, among other things, descriptions of the methods used to 
calculate emissions estimates, the rationale for selecting the methods 
used, and information about the complexity of methods and the 
resulting precision of the estimates; information on quality assurance 
procedures used; discussion of any recalculations affecting previously 
submitted inventory data; and information on improvements planned for 
future inventories. 

The Secretariat coordinates an inventory review process that, among 
other things, assesses the consistency of inventories from Annex I 
nations with reporting guidelines. The purposes of this process are to 
ensure that Parties are provided with (1) objective, consistent, 
transparent, thorough, and comprehensive assessments of the 
inventories; (2) adequate and reliable information on inventories from 
Annex I Parties; (3) assurance that inventories are consistent with 
IPCC reporting guidelines; and (4) assistance to improve the quality 
of inventories. 

In supporting the inventory review process, the Secretariat provides 
scientific and technical guidance on inventory issues and coordinates 
implementation of Convention guidelines. Inventory reviews are 
supervised by the head of the reporting, data, and analysis program 
within the Secretariat. By June each year, the Secretariat checks each 
inventory for completeness and format, called an initial check, and 
conducts a preliminary assessment before submitting it to an inventory 
review team for examination. The Secretariat assembles inventory 
review teams composed of scientists and other experts from around the 
world to review inventories from all Annex I Parties according to the 
Convention's review guidelines. The inventory review teams assess 
inventories in September by reviewing activity data, emissions 
factors, methodologies, and other elements of an inventory to 
determine if a nation has employed appropriate standards, 
methodologies, and assumptions to compute its emission estimates. From 
February through March, the inventory review teams develop inventory 
review reports outlining their findings. 

In accordance with the Convention's principle of common, but 
differentiated responsibilities, non-Annex I nations' inventories' 
format and frequency differ from those for Annex I nations. The 
reporting guidelines, which have evolved over time, encourage non-
Annex I nations to use the IPCC methodological guidelines in 
developing their inventories, but do not specify that they must be 
used. While they submit inventories to the Secretariat, non-Annex I 
nations' inventories are not stand-alone documents. Rather, a non-
Annex I nation's inventory is a component of its national 
communication, a report that discusses steps the nation is taking or 
plans to take to implement the Convention. Non-Annex I nations do not 
have to use the common reporting format or submit a national inventory 
report. Moreover, they do not submit an inventory each year, but 
instead the Parties to the Convention determine the frequency of their 
submissions. Parties have not agreed on a regular frequency for non-
Annex I nations to submit their inventories. 

Inventories From Seven Annex I Nations Were of Higher Comparability 
and Quality than Those From Seven Non-Annex I Nations Because of 
Several Barriers: 

According to expert inventory review teams, the 2009 greenhouse gas 
inventories of seven Annex I nations were generally comparable and of 
high quality, although some of their emissions estimates have 
substantial uncertainty. In contrast, we found that the most recent 
inventories from seven non-Annex I nations, although they met 
reporting guidelines, were of lower quality and generally not 
comparable. Finally, experts identified several barriers to improving 
inventory comparability and quality. 

Recent Reviews Found That Selected Annex I Nations' Inventories Were 
Comparable and of High Quality, but Some Estimates Have Substantial 
Uncertainty: 

All of the inventories submitted in 2009 by the seven selected Annex I 
nations were generally comparable and of high quality, according to 
the most recent inventory reviews conducted by expert review teams 
under the Convention. The reviews found that six of the seven nations--
Australia, Canada, Japan, Russia, the United Kingdom, and the United 
States--used appropriate methodologies and data, employed reasonable 
assumptions, and did not systematically either over-or underestimate 
emissions in their 2009 inventories (covering data from 1990 through 
2007). The one exception to this was Germany's 2009 inventory, which 
the review team said did not follow guidelines for its agricultural 
emissions, in part because of its attempt to use newer methods. The 
change significantly reduced estimated emissions from agriculture, 
though the sector is a relatively small contributor to Germany's total 
emissions. One inventory reviewer familiar with Germany's 2009 
inventory said its overall quality was fairly good. In addition, 
Germany appears to have addressed the issue of its agricultural 
emissions in its 2010 inventory submission by returning to its 
previous methods, which had the effect of increasing its estimates of 
emissions from agriculture.[Footnote 20] Experts said that the seven 
selected inventories were generally comparable, which means they 
generally used agreed-upon formats and methods. In addition, nine 
experts we interviewed said they were of high quality and did not have 
major flaws. 

These findings show significant improvement in the seven nations' 
inventories since our 2003 report. For example, we reported in 2003 
that both Germany's 2001 submission (covering data through 1999) and 
Japan's 2000 submission (covering data through 1998) lacked a national 
inventory report, a critical element that explains the data and 
methods used to estimate emissions. Nearly all Annex I nations--
including Germany and Japan--now routinely submit this report. In 
addition, the review team found Russia's 2009 inventory showed major 
improvements. For example, Russia included a full uncertainty analysis 
for the first time and improved its quality assurance and quality 
control plan. Since our 2003 report, these 7 selected nations, and 34 
other Annex I Parties, have submitted about seven inventories, which 
were generally on time and more comprehensive than previous 
inventories (see figure 3). 

Figure 3: Inventory Submissions from Annex I Parties, 1998-2010: 

[Refer to PDF for image: vertical bar graph] 

Year: 1998; 
Number of possible submissions: 39; 	
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
4; 
Total CFR submissions received: 21. 

Year: 1999; 
Number of possible submissions: 39; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
5; 
Total CFR submissions received: 28. 

Year: 2000; 
Number of possible submissions: 39; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
12; 
Total CFR submissions received: 32. 

Year: 2001; 
Number of possible submissions: 40; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
20; 
Total CFR submissions received: 32; 
National inventory reports received[A]: 18. 

Year: 2002; 
Number of possible submissions: 40; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
22; 
Total CFR submissions received: 37; 
National inventory reports received[A]: 23. 

Year: 2003; 
Number of possible submissions: 40; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
24; 
Total CFR submissions received: 36; 
National inventory reports received[A]: 30. 

Year: 2004; 
Number of possible submissions: 40; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
26; 
Total CFR submissions received: 38; 
National inventory reports received[A]: 37. 

Year: 2005; 
Number of possible submissions: 41; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
28; 
Total CFR submissions received: 40; 
National inventory reports received[A]: 38. 

Year: 2006; 
Number of possible submissions: 41; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
25; 
Total CFR submissions received: 41; 
National inventory reports received[A]: 41. 

Year: 2007; 
Number of possible submissions: 41; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
18; 
Total CFR submissions received: 41; 
National inventory reports received[A]: 40. 

Year: 2008; 
Number of possible submissions: 41; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
28; 
Total CFR submissions received: 41; 
National inventory reports received[A]: 40. 

Year: 2009; 
Number of possible submissions: 41; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
34; 
Total CFR submissions received: 41; 
National inventory reports received[A]: 41. 

Year: 2010; 
Number of possible submissions: 41; 
Data submitted in Common Reporting Format (CRF) by April 15 deadline: 
39; 
Total CFR submissions received: 41; 
National inventory reports received[A]: 41. 

Source: GAO analysis of Convention Secretariat information. 

Notes: In 2007, Parties submitted initial reports under the Kyoto 
Protocol. The effort to compile and review these reports may have 
contributed to the decline in on-time inventory submissions for 
surrounding years. 

[A] Reporting guidelines called for the preparation of national 
inventory reports beginning in 2000, but they were not collected prior 
to 2001. 

[End of figure] 

The inventory review reports noted several potential problems that, 
while relatively minor, could affect the quality of emissions 
estimates. For example, the review of the 2009 U.S. inventory noted 
that assumptions about the carbon content of coal are outdated because 
they are based on data collected between 1973 and 1989. The effect on 
emissions estimates is not clear, but the carbon content of the coal 
burned as fuel may change over time, according to the inventory review 
report. Any such change would affect emissions, since coal is the fuel 
for about half of all U.S. electricity generation.[Footnote 21] The 
U.S. inventory also used a value from a 1996 agricultural waste 
management handbook to estimate nitrous oxide emitted from livestock 
manure. The inventory review noted that livestock productivity, 
especially for dairy cows, has increased greatly since 1996, which 
would also increase each animal's output of nitrous oxide emissions. 
Using the IPCC's methodology for calculating emissions from excreted 
nitrogen, we estimated that this would lead to an underestimate of 
roughly 4.7 percent of total nitrous oxide emissions and 0.2 percent 
of total greenhouse gas emissions.[Footnote 22] Finally, the review of 
Russia's 2009 inventory noted that it did not include carbon dioxide 
emissions from organic forest soils, which the inventory review report 
said could be significant. The inventory reviews and one expert we 
interviewed attributed many of the potential underestimations to a 
lack of data or an adequate IPCC-approved methodology and said that 
nations were generally working to address the issues. 

Even though the review teams found these seven inventories generally 
comparable and of high quality, the nations reported substantial 
uncertainty in many of the emissions estimates in their inventories. 
The term "uncertainty" denotes a description of the range of values 
that could be reasonably attributed to a quantity.[Footnote 23] All of 
the Annex I nations' inventories we reviewed contained quantitative 
estimates of uncertainty. As shown in table 1, six of the seven 
nations reported uncertainties for their overall estimates between 
plus or minus 1 and 13 percent, and Russia reported overall 
uncertainty of about plus or minus 40 percent. That equates to an 
uncertainty of 800 million metric tons of carbon dioxide equivalent, 
slightly more than Canada's total emissions in 2007. Russia's 
relatively large uncertainty estimate could stem from several factors, 
such as less precise national statistics. In addition, Russia 
generally used aggregated national data rather than data that account 
for variation within the nation. This would increase uncertainty 
because aggregated data do not account for important differences that 
affect emissions, such as different types of technology used in the 
energy sector. Japan and Australia reported very low uncertainty in 
2009. The inventory review report noted that Japan's estimate was 
lower than estimates from other nations, but neither the report nor 
Japan's inventory provides a full explanation. The review team for 
Australia said that its uncertainty ranges were generally consistent 
with typical uncertainty ranges reported for its sectors. Despite high 
levels of uncertainty in some instances, the inventory review teams 
found the seven inventories to be generally of high quality because 
the teams judge quality based on consistency with guidelines rather 
than strictly on the precision of the estimates. 

Table 1: Estimates of Uncertainty Reported in Seven Annex I Nations' 
2009 Inventories for Emissions in 2007: 

Nation: Australia; 
Lower bound (percent): -2%; 
Upper bound (percent): +2%. 

Nation: Canada[A]; 
Lower bound (percent): -3%; 
Upper bound (percent): +6%. 

Nation: Germany; 
Lower bound (percent): -10%; 
Upper bound (percent): +10%. 

Nation: Japan; 
Lower bound (percent): -1%; 
Upper bound (percent): +1%. 

Nation: Russia; 
Lower bound (percent): -40%; 
Upper bound (percent): +40%. 

Nation: United Kingdom; 
Lower bound (percent): -13%; 
Upper bound (percent): +13%. 

Nation: United States; 
Lower bound (percent): -3%; 
Upper bound (percent): +7%. 

Source: National Inventory Reports of seven selected nations; 
inventory review report for Russia. 

[A] Canada's uncertainty analysis does not include uncertainty from 
the land-use, land-use change, and forestry sector. 

[End of table] 

The uncertainty of emissions estimates also varies among the different 
sectors of a nation's economy. For example, uncertainty is relatively 
low for estimates of carbon dioxide emissions from the combustion of 
fossil fuels because the data on fuel use are generally accurate and 
the process that generates emissions is well understood. Uncertainty 
is much higher for certain categories within agriculture and land-use. 
For example, some nations report that the uncertainty in their 
estimates of nitrous oxide emissions from agricultural soils is 
greater than 100 percent, in some cases much greater. According to a 
March 2010 report by a National Research Council committee, this 
results from scientific uncertainty in emission factors.[Footnote 24] 
Table 2 shows the contribution of the most important sources of 
uncertainty in the U.S. inventory. The sources of uncertainty in the 
other six Annex I nations' inventories follow a broadly similar 
pattern: the largest sources of uncertainty are either large sources 
of emissions--such as fossil fuel combustion and land use--or small 
but highly uncertain categories--such as agricultural soils. 

Table 2: Greenhouse Gas Emissions and Uncertainty for Selected 
Categories from the 2009 U.S. Inventory for Emissions in 2007: 

Emissions category: Carbon dioxide from combustion of fossil fuels; 
Emissions estimate (in millions of metric tons of carbon dioxide 
equivalent): 5,736; 
Uncertainty of the estimate (percent): -2% to +5%. 

Emissions category: Carbon dioxide from land use, land-use change, and 
forestry; 
Emissions estimate (in millions of metric tons of carbon dioxide 
equivalent): -1,063 (removal of carbon dioxide); 
Uncertainty of the estimate (percent): -15% to +18%. 

Emissions category: Nitrous oxide from agricultural soil management; 
Emissions estimate (in millions of metric tons of carbon dioxide 
equivalent): 208; 
Uncertainty of the estimate (percent): -22% to +53%. 

Emissions category: Methane from fermentation from digestion by 
livestock[A]; 
Emissions estimate (in millions of metric tons of carbon dioxide 
equivalent): 139; 
Uncertainty of the estimate (percent): -11% to +18%. 

Emissions category: Methane from landfills; 
Emissions estimate (in millions of metric tons of carbon dioxide 
equivalent): 133; 
Uncertainty of the estimate (percent): -39% to +33%. 

Emissions category: Methane from natural gas systems; 
Emissions estimate (in millions of metric tons of carbon dioxide 
equivalent): 105; 
Uncertainty of the estimate (percent): -24% to +43%. 

Source: GAO analysis of 2009 U.S. inventory. 

[A] The technical term for this is enteric fermentation. 

[End of table] 

Shortcomings in inventory reporting guidelines may decrease the 
quality and comparability of emissions estimates for land use, 
according to two experts we interviewed. For example, the guidelines 
state that nations should report all emissions from "managed forests," 
but they have broad latitude in assigning forested land to this 
category. This choice may have a major effect on emissions; one expert 
said that it would be possible for some nations with large forested 
areas, such as Brazil, to offset all their emissions from 
deforestation by designating large areas of protected forest as 
managed and taking credit for all of the carbon dioxide absorbed by 
those forests. To address this potential inconsistency, the National 
Research Council committee report recommended taking inventory of all 
land-based emissions and sinks for all lands, not just man-made 
emissions on managed lands. Others said that designating land as 
managed forest remains the most practical way to estimate man-made 
emissions and removals because other methods are not well developed. 

Inventories From Selected Non-Annex I Nations Met Guidelines but Were 
of Lower Quality and Generally Not Comparable: 

Inventories from the non-Annex I nations we reviewed met the 
Convention's relevant reporting guidelines. All of the seven non-Annex 
I nations we reviewed--Brazil, China, India, Indonesia, Malaysia, 
Mexico, and South Korea--had submitted their first inventories. In 
addition, Mexico submitted its second, third, and fourth inventories, 
and South Korea submitted its second.[Footnote 25] Secretariat 
officials said the other selected nations could submit their second 
inventories, as part of their national communications, over the next 
few years. The reporting guidelines call for non-Annex I nations to 
estimate emissions for 1990 or 1994 in their first submission, and for 
2000 in their second submissions, and to include estimates for carbon 
dioxide, methane, and nitrous oxide in all submissions. We found that 
all selected non-Annex I nations reported for relevant years and these 
three gases, but we did not assess whether nations used appropriate 
methodologies and assumptions to develop these estimates. 

However, the seven inventories were generally not comparable and were 
of lower quality than inventories from Annex I nations in four ways: 

1. Inventories from select non-Annex I nations were outdated. The most 
recent inventories from selected Annex I nations estimate emissions 
for 1990-2008. However, except for Mexico and South Korea, the most 
recently submitted inventories from selected non-Annex I nations are 
for emissions for 1994.[Footnote 26] (See figure 4.) 

Figure 4: Comparison of Most Recent Greenhouse Gas Emissions 
Inventories Submitted by Selected Annex I and Non-Annex I Nations: 

[Refer to PDF for image: illustrated table] 

Annex I: 
Groups of nations selected by GAO: Australia, Canada, Germany, Japan, 
Russia, United Kingdom, and the United States; 
Year(s) covered in inventory: 1990-2008; 
Coverage of gases: 
Carbon dioxide: [Check]; 
Methane: [Check]; 
Nitrous oxide: [Check]; 
Synthetic gases: [Check]; 
Estimate of uncertainty (percent): 1-40%. 

Non-Annex I: 
Groups of nations selected by GAO: Mexico; 
Year(s) covered in inventory: 1990-2006; 
Coverage of gases: 
Carbon dioxide: [Check]; 
Methane: [Check]; 
Nitrous oxide: [Check]; 
Synthetic gases: [Check]; 
Estimate of uncertainty (percent): 7%[A]. 

Groups of nations selected by GAO: South Korea; 
Year(s) covered in inventory: 1990-2003; 
Coverage of gases: 
Carbon dioxide: [Check]; 
Methane: [Check]; 
Nitrous oxide: [Check]; 
Synthetic gases: [Check]; 
Estimate of uncertainty (percent): Not estimated. 

Groups of nations selected by GAO: Brazil; 
Year(s) covered in inventory: 1990-1994; 
Coverage of gases: 
Carbon dioxide: [Check]; 
Methane: [Check]; 
Nitrous oxide: [Check]; 
Synthetic gases: [Check]; 
Estimate of uncertainty (percent): 22%. 

Groups of nations selected by GAO: Indonesia; 
Year(s) covered in inventory: 1990-1994; 
Coverage of gases: 
Carbon dioxide: [Check]; 
Methane: [Check]; 
Nitrous oxide: [Check]; 
Synthetic gases: [Empty]
Estimate of uncertainty (percent): Not estimated. 

Groups of nations selected by GAO: China, India, Malaysia; 
Year(s) covered in inventory: 1994; 
Coverage of gases: 
Carbon dioxide: [Check]; 
Methane: [Check]; 
Nitrous oxide: [Check]; 
Synthetic gases: [Empty] 
Estimate of uncertainty (percent): Not estimated. 

Source: GAO analysis of inventories. 

Note: We selected the seven largest emitting Annex I nations and seven 
of the largest emitting non-Annex I nations: 

[A] This uncertainty estimate is from Mexico's 2006 submission. Mexico 
did not include an uncertainty analysis in its latest inventory 
submitted in 2009. 

[End of figure] 

2. Some selected non-Annex I nations' inventories do not estimate 
emissions of all gases. As shown in figure 4, inventories from China, 
India, Indonesia, and Malaysia did not include estimates of the 
emissions of synthetic gases. Independent estimates show that while 
synthetic gases were only 1 percent of global emissions in 2005, the 
emissions of synthetic gases increased by 125 percent between 1990 and 
2005. Their emissions have also grown substantially in some non-Annex 
I nations, such as China, which had the largest absolute increase in 
synthetic gas emissions among all non-Annex I nations between 1990 and 
2005, according to information from the International Energy Agency 
(IEA).[Footnote 27] 

3. Select non-Annex I nations' inventories, to varying degrees, lacked 
critical elements. We assessed inventories for several elements that, 
according to reporting guidelines, can improve the quality and 
transparency of inventories. First, only Brazil and Mexico provided a 
quantitative analysis of the uncertainty of their estimates.[Footnote 
28] Second, we found that all inventories lacked adequate 
documentation of methodologies, emission factors, and assumptions and 
that most lacked descriptions of quality assurance and quality control 
measures. Third, none of the select nations reported in a comparable 
format, instead using different formats and levels of 
aggregation.[Footnote 29] For example, China estimated some methane 
emissions from various agricultural subsectors but grouped some of 
these estimates into only one category. In contrast, South Korea 
estimated these same emissions but reported them in separate 
categories. Overall, the lack of documentation and of a common 
reporting format limited our ability to identify and compare estimates 
across nations. Finally, only Mexico included an analysis of its key 
categories of emissions.[Footnote 30] 

4. National statistics from some select non-Annex I nations are less 
reliable. According to three experts we interviewed and literature, 
some non-Annex I nations have less reliable national statistics 
systems than most Annex I nations. These systems are the basis for 
emissions estimates, and experts noted that the estimates are only as 
good as the underlying data. For example, researchers estimated that 
the uncertainty of carbon dioxide emissions from China's energy sector 
was as high as 20 percent.[Footnote 31] In contrast, reported 
uncertainties in estimates of carbon dioxide emissions from fossil 
fuel use in many developed nations are less than 5 percent. In 
addition, the International Energy Agency noted a relatively large gap 
between its energy statistics and those used in the national 
inventories of some non-Annex I nations, highlighting a need for 
better collection of data and reporting of energy statistics by some 
non-Annex I nations.[Footnote 32] 

The lack of comparable, high quality inventories from non-Annex I 
nations is important because they represent the largest and the 
fastest growing portion of the world's emissions, and information 
about their emissions is important to international efforts to address 
climate change. (See figure 5.) For example, annual emissions from the 
seven selected non-Annex I nations grew by about 5 billion metric tons 
of carbon dioxide equivalent between 1990 and 2005, which was about 
the annual emissions of Canada, Germany, Japan, and Russia in 2005 
combined.[Footnote 33] Recognizing the importance of information from 
non-Annex I nations, in March 2010, a National Research Council 
committee recommended that Framework Convention Parties extend 
regular, rigorous inventory reporting and review to developing 
nations.[Footnote 34] 

Figure 5: Energy-Related Carbon Dioxide Emissions in Annex I and Non- 
Annex I Nations, 1992 through 2030, Actual and Projected: 

[Refer to PDF for image: multiple line graph] 

Metric tons in billions: 

Actual: 

Year: 1992; 
Annex I: 13.9; 
Non-Annex I: 7.6. 

Year: 1993; 
Annex I: 13.8; 
Non-Annex I: 7.9. 

Year: 1994; 
Annex I: 13.6; 
Non-Annex I: 8.3. 

Year: 1995; 
Annex I: 13.7; 
Non-Annex I: 8.5. 

Year: 1996; 
Annex I: 13.9; 
Non-Annex I: 8.8. 

Year: 1997; 
Annex I: 14.0; 
Non-Annex I: 9.2. 

Year: 1998; 
Annex I: 13.9; 
Non-Annex I: 9.2. 

Year: 1999; 
Annex I: 14.1; 
Non-Annex I: 9.3. 

Year: 2000; 
Annex I: 14.4; 
Non-Annex I: 9.5. 

Year: 2001; 
Annex I: 14.3; 
Non-Annex I: 9.7. 

Year: 2002; 
Annex I: 14.4; 
Non-Annex I: 10.4. 

Year: 2003; 
Annex I: 14.7; 
Non-Annex I: 11.2. 

Year: 2004; 
Annex I: 14.9; 
Non-Annex I: 12.7. 

Year: 2005; 
Annex I: 15.0; 
Non-Annex I: 13.5. 

Year: 2006; 
Annex I: 15.0; 
Non-Annex I: 14.1. 

Year: 2007; 
Annex I: 15.0; 
Non-Annex I: 14.8. 

Year: 2008; 
Annex I: 14.9; 
Non-Annex I: 15.5. 

Year: 2009; 
Annex I: 14.8; 
Non-Annex I: 15.8. 

Projected: 

Year: 2010; 
Annex I: 14.7; 
Non-Annex I: 16.0. 

Year: 2011; 
Annex I: 14.6; 
Non-Annex I: 16.2. 

Year: 2012; 
Annex I: 14.6; 
Non-Annex I: 16.5. 

Year: 2013; 
Annex I: 14.5; 
Non-Annex I: 16.7. 

Year: 2014; 
Annex I: 14.4; 
Non-Annex I: 16.9. 

Year: 2015; 
Annex I: 14.3; 
Non-Annex I: 17.2. 

Year: 2016; 
Annex I: 14.4; 
Non-Annex I: 17.6. 

Year: 2017; 
Annex I: 14.4; 
Non-Annex I: 18.1. 

Year: 2018; 
Annex I: 14.4; 
Non-Annex I: 18.5. 

Year: 2019; 
Annex I: 14.4; 
Non-Annex I: 18.9. 

Year: 2020; 
Annex I: 14.4; 
Non-Annex I: 19.4. 

Year: 2021; 
Annex I: 14.5; 
Non-Annex I: 19.9. 

Year: 2022; 
Annex I: 14.5; 
Non-Annex I: 20.4. 

Year: 2023; 
Annex I: 14.6; 
Non-Annex I: 20.8. 

Year: 2024; 
Annex I: 14.6; 
Non-Annex I: 21.3. 

Year: 2025; 
Annex I: 14.6; 
Non-Annex I: 21.8. 

Year: 2026; 
Annex I: 14.7; 
Non-Annex I: 22.3. 

Year: 2027; 
Annex I: 14.8; 
Non-Annex I: 22.8. 

Year: 2028; 
Annex I: 14.8; 
Non-Annex I: 23.3. 

Year: 2029; 
Annex I: 14.9; 
Non-Annex I: 23.8. 

Year: 2030; 
Annex I: 14.9; 
Non-Annex I: 24.4. 

Source: GAO analysis of Energy Information Administration data. 

Note: Does not include Monaco or Lichtenstein, which are both Annex I 
nations. These accounted for less than one percent of Annex I nations' 
emissions in 2007 according to inventory data submitted to the 
Convention Secretariat. 

[End of figure] 

Experts Identified Several Barriers to Improving the Comparability and 
Quality of Inventories: 

Experts we interviewed identified several barriers to improving the 
comparability and quality of inventories. First, 10 of the 12 experts 
who provided views about barriers said that a lack of data and 
scientific knowledge makes some types of emissions difficult to 
estimate for both Annex I and non-Annex I nations.[Footnote 35] For 
example, current estimates of emissions related to biological 
processes, such as those from agriculture and land use, can be 
uncertain because of limited data. Specifically, nations do not always 
collect data on livestock nutrition, which can affect methane 
emissions. In addition, emissions related to some biological processes 
are difficult to estimate because they are not fully understood or are 
inherently variable. Emissions related to agriculture, for example, 
depend on the local climate, topography, soil, and vegetation. In 
March 2010, a National Research Council committee recommended further 
scientific research and data collection to reduce the uncertainties in 
estimates of agriculture, forestry, and land-use emissions.[Footnote 
36] Such emissions are important, contributing about one quarter of 
total global emissions in 2005, the most recent year for which global 
data were available. They are particularly important for some non-
Annex I nations, where they can be the largest sources of emissions. 
In Brazil and Indonesia, for example, agriculture and land-use 
emissions accounted for about 80 percent of total emissions in 2005. 

Second, 11 experts said that non-Annex I nations have limited 
incentives to produce better inventories. The current international 
system encourages Annex I nations with commitments under the Kyoto 
Protocol to improve their inventories.[Footnote 37] This is because 
their ability to participate in the Kyoto Protocol's flexibility 
mechanisms--which provide a cost-effective way to reduce emissions--is 
linked to, among other things, the quality of certain aspects of their 
inventories.[Footnote 38] Late submissions, omissions of estimates, or 
other shortcomings can all affect nations' eligibility to use these 
mechanisms.[Footnote 39] Therefore, low-quality inventories can affect 
nations' ability to lower the costs of achieving their emissions 
targets. While four experts we interviewed said that this linkage 
between inventories and the flexibility mechanisms in the Kyoto 
Protocol has driven improvements in many Annex I nations' inventories, 
incentives for non-Annex I nations are limited. Furthermore, four 
experts said that some non-Annex I nations may avoid additional 
international reporting because they see it as a first step toward 
adopting commitments to limit emissions. 

In addition, experts and the national communications of selected non- 
Annex I nations identified several other barriers to improving the 
quality and comparability of inventories from non-Annex I nations, 
including: 

* Less stringent reporting guidelines and lack of review. Reporting 
guidelines differ between Annex I and non-Annex I nations. Non-Annex I 
nations do not need to annually submit inventories or to report on as 
many gases, for as many years, with as much detail, or in the same 
format as Annex I nations. They also do not have to follow all IPCC 
methodological guidelines, although they are encouraged to do so. Six 
experts said that this less stringent reporting regime has contributed 
to the lack of quality and comparability in inventories from non-Annex 
I nations. In addition, non-Annex I nations have not benefited from 
the feedback of technical reviews of their inventories, according to 
one expert. 

* Financial and other resource constraints. Though eight experts 
generally said that many non-Annex I nations may lack needed financial 
and other resources, they differed on the magnitude and importance of 
additional international support. Non-Annex I nations may lack 
resources to improve data collection efforts, conduct additional 
research, or establish national inventory offices. The developed 
nations of Annex I provided the majority of about $80 million that has 
been approved for the latest set of national communications, which 
include inventories, from non-Annex I nations. However, one expert 
said that this has not been sufficient to fully support the activities 
needed. In their national communications, China and India indicated 
needing funding to, for example, improve data collection. Two experts 
said that improving non-Annex I nations' inventories may require 
significant resources. On the other hand, others said that the funds 
involved may be relatively small, or that financial constraints may 
not be significant, at least for major non-Annex I nations. For 
example, according to a report from a National Research Council 
committee, significant improvements in inventories from 10 of the 
largest emitting developing nations could be achieved for about $11 
million over 5 years.[Footnote 40] While experts disagreed about the 
importance of additional funding, three said that international 
funding should support capacity development in each nation. They said 
that more continuous support would improve on the current, project-
based method of funding, which encourages nations to assemble ad-hoc 
teams that collect data, write a report, and then disband. 

* Lack of data and nation-specific estimates of emissions factors. 
According to four experts and the Convention Secretariat's summary of 
constraints identified by non-Annex I nations in their initial 
national communications, the lack or poor quality of data or a 
reliance on default emissions factors limit the quality of 
inventories. Most non-Annex I nations identified that missing or 
inadequate data was a major constraint for estimating emissions in at 
least one sector. For example, Indonesia reported that it did not 
estimate carbon emissions from soils because the data required were 
not available. Though inventory guidelines encourage the use of nation-
specific emissions factors that reflect national circumstances, most 
non-Annex I nations use default values provided by the IPCC. The 
reliance on default values can increase uncertainties of estimates 
because national circumstances can differ significantly from the 
defaults. For example, Denmark's nation-specific emission factor for 
methane emissions from sheep is twice as large as the default. Thus, 
if Denmark had used the default value, it would have underestimated 
its emissions from sheep by half. 

The Inventory Review Process for Annex I Nations Has Several Strengths 
and Some Limitations, and No Comparable Process Exists for Non-Annex I 
Nations: 

Experts said that the process for reviewing inventories from Annex I 
nations has several notable strengths. They also identified three 
limitations, which may present challenges in the future. Moreover, we 
found that although the review process includes steps to help ensure 
the quality of reviews, there is no independent assessment of the 
process' operations. Finally, there is no review process for 
inventories from non-Annex I nations. 

The Process for Reviewing Inventories from Annex I Nations Has Several 
Strengths: 

Eight of the experts we interviewed said the process for reviewing 
inventories from Annex I nations has several notable strengths that 
enable it to generally meet its goals of providing accurate 
information on the quality of inventories and helping nations improve 
their inventories.[Footnote 41] (Figure 6 below depicts the inventory 
review process.) 

Figure 6: Review Process for Inventories from Annex I Nations: 

[Refer to PDF for image: illustration] 

Annex I nations: 
Develop and submit annual greenhouse gas inventories to the Convention 
Secretariat in Bonn, Germany, due by April 15. 

Convention Secretariat: 
* Reviews inventories for completeness and format; 
* Compares basic inventory information and carries out preliminary 
assessment of each inventory, due by June; 
* Assembles inventory review teams to conduct reviews (identifies lead 
reviewers and assigns a Secretariat review officer for each team). 

Convention Secretariat: 
* Provides general management supervision of the review process; 
* Oversees review officers, lead reviewers, and review teams, and 
tracks potential inventory issues via review transcripts; 
* Designates a Quality Control Officer and supervisor to read all 
draft inventory review reports. 
Inventory review team: 
* Review inventories, examining such elements as methodologies used, 
documentation, appropriateness of assumptions, and documenting issues 
and their resolution in review transcript; 
* Develop inventory review reports; 
* Include lead reviewers who, with support from Secretariat, aim to 
ensure reviews are performed in accordance with guidelines. 

Source: GAO analysis of Convention documents and interviews with 
Secretariat officials. 

[End of figure] 

Experts identified four broad categories of strengths: 

* Rigorous review process. Five experts said the rigorous review 
process gives them confidence that review teams can identify major 
problems with inventory estimates. For example, the Secretariat and 
review teams compare data, emission factors, and estimates from each 
inventory (1) from year to year, (2) with comparable figures in other 
inventories, and (3) with data from alternative sources, such as the 
International Energy Agency (IEA) and the United Nations Food and 
Agriculture Organization. Reviewers also ensure methods used to 
estimate emissions are appropriate and meet accepted guidelines. In 
addition, IEA officials inform the inventory review process by 
reviewing energy data in inventories and independently identifying 
issues for review teams to consider further. 

* Qualified and respected reviewers. Three experts we interviewed said 
that well-qualified and widely respected inventory reviewers give the 
process credibility. Secretariat officials told us that a relatively 
small number of people in the world have the expertise to evaluate 
inventories without further training. Parties nominate reviewers, 
including leading scientists and analysts, many of whom are also 
inventory developers in their home nations. Reviewers must take 
training courses and pass examinations that ensure they understand 
inventory guidelines and appropriate methodologies before serving on a 
review team. Two experts said reviewers' experience and qualifications 
allow them to assess the strengths and weaknesses in inventories, 
including whether nations use appropriate methodologies. This is 
particularly important because some nations use advanced or nation- 
specific approaches, which can be difficult to assess. 

* Capacity building. Three experts said the inventory review process 
builds expertise among reviewers from developed and developing 
nations. Specifically, they said the review process brings inventory 
specialists together from around the world, where they learn from each 
other and observe how various nations tackle challenges in compiling 
their inventories. Two experts said that reviewers return home and can 
use the knowledge and contacts gained from their review team 
experiences to improve their national inventories. 

* Constructive feedback. Two experts said that the inventory reviews 
provide constructive feedback to improve inventories from Annex I 
nations. This feedback includes identifying both major and minor 
shortcomings in inventories. Secretariat officials said that review 
teams, when they identify issues, must also offer recommendations for 
addressing them. For example, reviewers noted Russia's 2009 use of 
default assumptions for much of its uncertainty analysis, and 
recommended that Russia develop values that better match the methods 
and data used in making the emissions estimates. 

For these and other reasons, three experts we interviewed said that 
the review process has helped improve the quality of inventories from 
Annex I nations. Secretariat officials said that when review teams 
point out discrepancies or errors, many nations revise and resubmit 
estimates to correct problems. For example, Australia revised its 
estimates of carbon dioxide emissions from croplands after a review 
team pointed out that changes in croplands management affect 
emissions. Australia's revisions decreased estimated emissions from 
croplands in 1990 by 138 percent, meaning the revisions had the effect 
of moving croplands from an estimated source of greenhouse gas 
emissions to a sink removing greenhouse gases from the atmosphere. For 
nations with Kyoto Protocol commitments, review teams may adjust 
estimates if they are not satisfied with a response to their findings. 
[Footnote 42] For example, the team reviewing Greece's 2006 inventory 
concluded that estimates in several categories were based on methods, 
data, and emissions factors that did not adhere to reporting 
guidelines. The review team was not satisfied with Greece's response, 
and recommended six adjustments to Greece's estimates. These 
adjustments lowered Greece's official baseline energy sector emissions 
by 5 percent, from 82 million to 78 million metric tons of carbon 
dioxide equivalent.[Footnote 43] 

The Process for Reviewing Inventories from Annex I Nations Has Some 
Limitations: 

Experts, literature, and several nations identified some limitations 
of the review process, which may present challenges in the future if, 
for example, the process is expanded to incorporate non-Annex I 
nations. First, six experts we interviewed said the process does not 
independently verify emissions estimates or the quality of the 
underlying data. Review teams primarily ensure the consistency of 
inventories with accepted standards but do not check underlying 
activity data, such as the amount of fuel burned. Review teams do 
compare underlying data with those reported in other sources, but 
these other sources are not fully independent because they also come 
from the nations that supply the inventories. Two experts said that 
more thorough verification might involve comparing estimates to 
observed measurements or independently constructing estimates from raw 
data. 

However, such approaches may be costly and, as a National Research 
Council committee reported, the other methods currently available do 
not allow independent verification of estimates. Furthermore, one 
expert said that the review of emissions estimates from agricultural 
soils and land-use sectors may be especially limited because of a lack 
of data and the inherent difficulty in measuring these emissions. The 
inability to more thoroughly assess inventories may reduce the 
reliability of review findings. For example, the inventory review 
process may have overlooked a significant shortcoming in at least one 
review. Specifically, in 2009, the national audit office of one Annex 
I nation found that its national inventory estimates may understate 
actual emissions by about a third because the inventory preparers used 
questionable statistics. The relevant agencies in that nation 
generally agreed with the audit office's recommendations based on its 
assessment. The review for that inventory, however, did not identify 
this issue. 

Second, four experts we interviewed and several nations have expressed 
concerns about inconsistency across reviews, though the magnitude of 
this potential problem is unclear. The concerns relate to the 
potential for review teams to inconsistently apply standards when 
assessing an inventory. Secretariat officials said the process of 
reviewing inventories involves some degree of subjectivity, since 
reviewers use professional judgment in applying inventory review 
guidelines to a specific inventory. As a result, review teams might 
interpret and apply the guidelines differently across nations or over 
time. Four experts we spoke with, as well as several nations, have 
raised such concerns. For example, the European Community reported 
that some nations have received, on occasion, contradictory 
recommendations from inventory review teams.[Footnote 44] Secretariat 
officials said lead reviewers are ultimately responsible for 
consistent reviews but that Secretariat staff assist the review teams 
during the process, and two Secretariat staff read through all draft 
inventory reports, in part to identify and resolve possible 
inconsistencies. In addition, lead reviewers develop guidance on 
consistency issues at annual meetings. The magnitude of this potential 
problem is unclear, in part because it has not been evaluated by an 
independent third party. 

Third, three experts and officials we interviewed said there are not 
enough well-qualified reviewers to sustain the process. Three experts 
and Secretariat officials said that they did not know whether this 
shortage of available experts has affected the overall quality of 
reviews. The Secretariat has, in the past, reassigned staff and 
reviewers from work on national communications to the review of 
inventory reports, and it provides training to all reviewers to 
increase capacity and retain qualified reviewers. However, Secretariat 
officials said it may be difficult to sustain the quality of reviews 
in the future if the inventory review process is expanded to include 
inventories from non-Annex I nations without receiving additional 
resources, since this would substantially increase the demands on the 
review process. 

The Review Process Does Not Have an Independent Assessment of Its 
Operations: 

The review process includes steps to help ensure the quality of 
reviews, but we found that its quality assurance framework does not 
independently assess the process. Secretariat officials said that lead 
reviewers oversee the drafting of review reports, and review officers, 
lead reviewers, and review teams maintain a review transcript to keep 
track of potential issues they have identified with inventories, of 
nations' responses to those issues, and of their resolution. However, 
lead reviewers, in the report of their 2009 meeting, expressed concern 
that these review transcripts are sometimes incomplete and are not 
always submitted to the Secretariat. In providing information on their 
experience with the review process and recommendations for 
improvements, the nations of the European Community suggested in late 
2008 that the review process would benefit from establishing clear 
quality assurance and quality control procedures as well as from an 
annual analysis of its performance in relation to its objectives. 
[Footnote 45] Secretariat officials said they designated a Quality 
Control Officer who, along with the supervisor of the review process, 
reads all draft review reports and may identify problems and check 
underlying information in reports. Furthermore, Secretariat officials 
said that lead reviewers meet annually to discuss the review process, 
assess and prepare guidance about specific issues or concerns about 
the review process, and develop summary papers to report to Parties. 

Nonetheless, the review process lacks an independent assessment of its 
operation. We examined several other review processes and found that 
periodic external assessments by independent entities can provide 
useful feedback to management and greater assurance that the review 
processes are working as intended.[Footnote 46] Inventory guidelines 
call for Annex I nations to carry out quality assurance activities for 
their own inventories, including a planned system of reviews by 
personnel not directly involved in the process.[Footnote 47] Though 
some United Nations and Framework Convention oversight bodies have the 
ability to assess the inventory review process, none have done so. 
[Footnote 48] The Secretariat has internal auditors, but they have not 
audited the inventory review process and Secretariat officials said 
they did not know of any plans to do so. Although the Compliance 
Committee of the Kyoto Protocol has reviewed aspects of the review 
process, issuing a report with information on consistency issues, this 
report was not a systematic review and was not developed by people 
independent of the review process. 

No Inventory Review Process Exists for Non-Annex I Nations: 

As stated earlier, inventories from non-Annex I nations do not undergo 
formal reviews. The Secretariat compiled a set of reports summarizing 
inventory information reported by non-Annex I nations, such as 
inventory estimates, national circumstances, and measures to address 
climate change.[Footnote 49] However, Secretariat officials said they 
had not assessed the consistency of non-Annex I nations' inventories 
with accepted guidelines. These officials also said that they did not 
plan to compile another report covering non-Annex I nations' second 
inventories because the Parties have not agreed to this. An expert we 
interviewed said that the quality of inventories from non-Annex I 
nations is unknown because their inventories have not been formally 
reviewed. Two experts said that some non-Annex I nations have resisted 
increased scrutiny of their inventories because of sovereignty 
concerns, meaning that nations do not want to disclose potentially 
sensitive information or data to other political bodies. The growth in 
greenhouse gas emissions along with lower quality inventories in some 
non-Annex I nations is likely to increase the pressure for a public 
review of their inventories in the future. 

Experts Said the Inventory System Is Generally Sufficient for 
Monitoring Compliance with Current Agreements, but Future Agreements 
with Non-Annex I Nations Could Pose Challenges: 

Most experts we interviewed said that the inventory system for Annex I 
and non-Annex I nations is generally sufficient for monitoring 
compliance with current agreements. However, they said that the system 
may not be sufficient for monitoring non-Annex I nations' compliance 
with future agreements that include commitments for them to reduce 
emissions. 

Experts Said the Inventory System Supports Current Agreements and 
International Negotiations: 

Eleven of the experts we interviewed said the inventory system-- 
inventories and the process for reviewing them--is generally 
sufficient for monitoring compliance with current agreements, though 
five raised some concerns. All 11 of the experts who provided their 
views on the implications of the inventory system expressed confidence 
that inventories and the Convention's inventory review process are 
suitable for monitoring Annex I nations' compliance with existing 
commitments to limit emissions.[Footnote 50] In part, this is because 
emissions in many Annex I nations primarily relate to energy and 
industrial activity, which can be more straightforward to estimate and 
monitor than emissions from land use and agriculture. 

Nevertheless, five experts raised at least one of two potential 
challenges facing the current system. First, three said they were 
cautious until they see how the system performs under the more 
demanding conditions of submitting and reviewing inventories that will 
show whether nations have met their binding emission targets under the 
Kyoto Protocol.[Footnote 51] When inventories are for years included 
in the Protocol's commitment period, nations may be more concerned 
about meeting emissions targets, and review teams may face pressure to 
avoid negative findings. Second, three experts said that flexibilities 
in the current inventory system or difficulties in measuring and 
verifying emissions from some agriculture and land-use segments could 
create complications for international emissions trading under the 
Kyoto Protocol. Emissions trading under the Kyoto Protocol allows 
nations with emissions lower than their Kyoto targets to sell excess 
allowances to nations with emissions exceeding their targets. Though 
Parties to the Kyoto Protocol developed and agreed to the current 
system, three experts indicated that ensuring greater comparability of 
estimates between nations and types of emissions might be useful for 
emissions trading.[Footnote 52] For non-Annex I nations, eight experts 
said that their lower quality inventories and lack of review do not 
present a current problem since these nations do not have 
international commitments to limit their emissions. 

Seven of the experts said that the inventory system is sufficient to 
support international negotiations. To develop agreements, two experts 
said, negotiators need information on current and historic emissions 
from the nations involved. Annex I nations submit this information in 
their annual emissions inventories, the most recent of which cover 
emissions from 1990 to 2008. Although emissions estimates in most non- 
Annex I nations' inventories are outdated, seven experts said that 
there are enough independent estimates to provide negotiators with 
adequate information.[Footnote 53] State officials said that 
independent estimates are useful, but official national inventories 
would be preferable because they can lead to more constructive 
discussions and can help create capacity in nations to better measure 
emissions. In international negotiations, State has emphasized the 
need for better information on emissions from all high-emitting 
nations, including non-Annex I nations. 

Experts Said the Inventory System May Not Be Sufficient for Monitoring 
Non-Annex I Nations' Compliance with Future Agreements, Though Other 
Barriers Pose Greater Challenges: 

Different types of commitments would place different demands on the 
inventory system. Thus, the implications of the state of the inventory 
system for a future agreement will largely depend on the nature of 
that agreement. For Annex I nations, eight experts said that future 
commitments were likely to resemble current commitments and therefore 
the inventory system is likely to be sufficient. However, for non-
Annex I nations, if future agreements include commitments to limit 
emissions, the current system is not sufficient for monitoring their 
compliance, according to nine experts. This is because non-Annex I 
nations do not submit inventories frequently, the quality of their 
inventories varies, and they do not undergo an independent technical 
review. Additional reporting and review could pose challenges since it 
could take time for non-Annex I nations to improve their inventories 
and Secretariat officials said that adding non-Annex I nations to the 
current inventory review process could strain the capacity of that 
system. 

Some types of commitments by non-Annex I nations could be especially 
difficult to monitor and verify, according to experts. In the 
nonbinding 2009 Copenhagen Accord, many nations submitted the actions 
they intended to take to limit their greenhouse gas emissions, with 
Annex I nations committing to emissions targets for 2020 and non-Annex 
I nations announcing various actions to reduce emissions. Experts 
identified several challenges with monitoring the implementation of 
some of the actions proposed by non-Annex I nations (see table 3). For 
example, two experts said that monitoring emissions reductions from 
estimates of future business-as-usual emissions may prove challenging. 
They said this is because such actions may require Parties to estimate 
reductions from a highly uncertain projection of emissions that would 
have otherwise occurred. Parties would also have to develop and agree 
on guidelines to estimate and review business-as-usual emissions in 
addition to actual emissions. Similarly, monitoring reductions in the 
intensity of greenhouse gas emissions--emissions per unit of economic 
output, or gross domestic product--could pose challenges because of 
uncertainties in estimates of gross domestic product. One expert said 
that these challenges arise because the Parties to the Convention 
created the current inventory system to monitor compliance and 
evaluate progress among Annex I nations with national targets. This 
expert added that Parties to a new agreement may need to supplement 
the system to support the types of actions under consideration by non-
Annex I nations. 

Table 3: Select Actions Submitted Under the Copenhagen Accord and 
Potential Challenges Identified by Experts: 

Annex I nations: 

Type of action: National emissions targets; 
Examples: 
* 5-25 percent reduction from 2000 levels by 2020 (Australia)[A]; 
* 17 percent reduction from 2005 levels by 2020 (Canada)[A]; 
* 15-30 percent reduction from 1990 levels by 2020 (European Union, 
Japan, and Russia)[A]; 
* In the range of a 17 percent reduction from 2005 levels by 2020 
(United States)[A]; 
Potential challenges identified by experts: 
* Some issues to be resolved related to reporting land-use, land-use 
change, and forestry emissions; 
* Some concerns about using current inventories to support 
international emissions trading. 

Non-Annex I nations--nationally appropriate mitigation actions: 

Type of action: Reductions from business-as-usual; 
Examples: 
* Up to 30 percent reduction from business-as-usual by 2020 (Mexico); 
* 30 percent reduction from business-as-usual by 2020 (South Korea); 
* 36-39 percent reduction from projected emissions by 2020 (Brazil); 
Potential challenges identified by experts: 
* Would require new guidelines, reporting, and review for business-as-
usual emissions projections; 
* Non-Annex I inventories are infrequent, less comprehensive, and are 
not reviewed; 
* Additional reviews could strain capacity of current system. 

Type of action: Sector-level targets and timetables; 
Examples: 
* Reduction in emissions related to deforestation (Brazil); 
Potential challenges identified by experts: 
* May require new guidelines if sectors are not the same as defined in 
current guidelines; 
* Would require reporting and review of sector-level emissions; 
* Focus on forestry may present additional challenges. 

Type of action: Intensity targets; 
Examples: 
* 40-45 percent reduction in carbon dioxide emissions per unit of 
gross domestic product (GDP) by 2020 compared to 2005 (China); 
* 20-25 percent reduction in emissions intensity of GDP by 2020 
compared to 2005 (India); 
Potential challenges identified by experts: 
* Would require new guidelines, reporting, and reviewing for GDP 
figures; 
* Non-Annex I inventories are infrequent, less comprehensive, and are 
not reviewed; 
* Additional reviews could strain capacity of current system. 

Type of action: Policies and measures; 
Examples: 
* Promotion of energy efficiency (Indonesia); 
Potential challenges identified by experts: 
* Would require new guidelines, reporting, and review. 

Source: GAO analysis based submissions to the Convention Secretariat 
and interviews with experts. 

Note: This list represents challenges identified by one or more 
experts. 

[A] All listed Annex I actions are conditional on actions by others, 
or, for the United States, on anticipated energy and climate 
legislation. 

[End of table] 

Eight of the experts we interviewed said that Parties to a future 
agreement could overcome or mitigate many of the challenges related to 
inventories. For example, two experts said that Parties could design 
agreements that rely less on emissions estimates that are inherently 
uncertain or difficult to verify. For example, quantitative targets 
could apply only to sectors or gases that are relatively easy to 
measure and verify, such as carbon dioxide emissions from the burning 
of fossil fuels. 

Three experts said that barriers other than the inventory system pose 
greater challenges to designing and reaching agreements on climate 
change. For example, nations disagree on the appropriate emissions 
limits for developed and developing nations. According to three 
experts, such disagreements were more of an obstacle to a 
comprehensive agreement in the latest round of negotiations in 
Copenhagen than were inventory issues. In addition, one expert pointed 
out that Parties to international agreements generally have limited 
ability to get other Parties to comply. For example, at least one 
nation with a binding emissions target under the Kyoto Protocol is 
unlikely to meet its target based on current inventory estimates and 
policies, according to this expert. Nations may be reluctant to agree 
to an international agreement until they have some assurance that 
other nations will follow through on their commitments. 

Conclusions: 

High quality and comparable information on national greenhouse gas 
emissions is critical to designing and implementing international 
responses to climate change. The nations we reviewed meet their 
inventory reporting obligations, and review reports indicate this has 
resulted in generally high quality inventories from the seven highest 
emitting Annex I nations. However, the current inventory system does 
not request high quality emissions information from non-Annex I 
nations, which account for the largest and fastest growing share of 
global emissions. We found that the inventories from seven selected 
high emitting non-Annex I nations were generally outdated, not 
comparable, and of lower quality than inventories from Annex I 
nations. The existing gap in quality and comparability of inventories 
across developed and developing nations makes it more difficult to 
establish and monitor international agreements, since actions by both 
developed and developing nations will be necessary to address climate 
change under future international agreements. As a recent National 
Research Council committee study pointed out, extending regular 
reporting and review to more nations may require external funding and 
training, but the resources needed for the largest emitting developing 
nations to produce better inventories is relatively modest. 

While our work suggests that the current inventory review process has 
notable strengths, we identified limitations that may present 
challenges in the future. For example, some experts and nations have 
reported concerns about inconsistent reviews and that resources may 
not be sufficient in the future. Stresses on the review process are 
likely to increase as review teams begin to review inventories that 
cover years in which some nations have binding emissions targets and 
if inventories from non-Annex I nations are subjected to inventory 
review under a future agreement. The Convention Secretariat has 
internal processes in place to help ensure quality reviews, but no 
systematic independent review to assess the merits of concerns about 
the consistency of reviews or to assess the need for additional 
qualified reviewers in the future. Addressing these issues could 
benefit the Secretariat by further enhancing confidence in its 
processes and ensuring that it has the resources necessary to maintain 
high quality reviews. 

Recommendations for Executive Action: 

We are making two recommendations to the Secretary of State: 

1. Recognizing the importance of high quality and comparable data on 
emissions from Annex I and non-Annex I Parties to the Convention in 
developing and monitoring international climate change agreements, we 
recommend that the Secretary of State continue to work with other 
Parties to the Convention in international negotiations to encourage 
non-Annex I Parties, especially high-emitting nations, to enhance 
their inventories, including by reporting in a more timely, 
comprehensive, and comparable manner, and possibly establishing a 
process for reviewing their inventories. 

2. To provide greater assurance that the review process has an 
adequate supply of reviewers and provides consistent reviews, we 
recommend that the Secretary of State, as the U.S. representative to 
the Framework Convention, work with other Parties to the Convention to 
explore strengthening the quality assurance framework for the 
inventory review process. A stronger framework could include, for 
example, having an independent reviewer periodically assess the 
consistency of inventory reviews and whether the Secretariat has 
sufficient resources and inventory reviewers to maintain its ability 
to perform high quality inventory reviews. 

Agency Comments and Third-Party Views: 

We provided State, the Convention Secretariat, and EPA with a draft of 
this report for review and comment. State agreed with our findings and 
recommendations and said that the department has been working with 
international partners in negotiations and through bilateral and 
multilateral partnerships to support and promote improved inventory 
reporting and review. State's comments are reproduced in appendix III. 

The Convention Secretariat provided informal comments and said that it 
appreciated our findings and conclusions. The Secretariat said that 
the report provided a comprehensive overview of the existing system 
for reporting and reviewing inventories under the Convention and the 
Kyoto Protocol, as well as very useful recommendations on how this 
system could evolve in the future and steps to be taken to that end. 
The Secretariat noted our acknowledgment of the strengths of the 
inventory review process for Annex I nations. In addition, the 
Secretariat commented on our discussion of the limited availability of 
statistics against which to compare inventory data, saying that this 
lack of data does not imply that its review process lacks independent 
verification and that its review teams rely on available statistics in 
conducting their reviews. The Secretariat also said that the 
disparities in inventory quality across Annex I and non-Annex I 
nations should be viewed in the context of the "common but 
differentiated responsibilities" of developed and developing nations 
under the Convention. 

In addition, EPA and the Convention Secretariat provided technical 
comments and clarifications, which we incorporated as appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
appropriate congressional committees, Secretary of State, 
Administrator of EPA, Executive Secretary of the Convention 
Secretariat, and other interested parties. In addition, the report 
will be available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-3841 or stephensonj@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. GAO staff who made key 
contributions to this report are listed in appendix IV. 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Scope and Methodology: 

Our review provides information on: (1) the comparability, quality, 
and barriers to improving inventories submitted by developed and 
developing nations to the United Nations Framework Convention on 
Climate Change (the Convention); (2) the strengths and limitations of 
the Convention's inventory review process; and (3) the views of 
experts on the implications for agreements to reduce greenhouse gas 
emissions. To address all of these objectives, we reviewed relevant 
literature and Convention documents; met with officials from the 
Environmental Protection Agency (EPA), Department of State (State), 
the Convention Secretariat, and others to understand inventories, the 
inventory review process, and international negotiations; and 
summarized the views of experts on these issues. 

Specifically, to address the first objective, we selected a 
nonprobability sample of 14 nations, seven Annex I nations--Australia, 
Canada, Germany, Japan, Russia, the United Kingdom, and the United 
States--and seven non-Annex I nations--Brazil, China, India, 
Indonesia, Malaysia, Mexico, and South Korea--based on the size of 
their emissions (including emissions from land-use and land-use change 
and forestry). We selected the largest emitting Annex I nations. For 
non-Annex I nations, we selected the largest emitting nations who had 
submitted inventories based on data available at the time.[Footnote 
54] We omitted Myanmar because it did not submit an inventory to the 
Convention. We also ensured coverage of major variations in selected 
nation's income and sectoral structure of their economies. To 
illustrate this variation, we used the World Bank's data on per capita 
income levels, and data from the World Resources Institute and 
Convention Secretariat on emissions from the energy and industrial 
processes sectors. The selected 14 nations represented about two 
thirds of the world's greenhouse gas emissions not related to land use 
and forestry in 2005. Our findings are not generalizable to other 
nations because the selected nations are not necessarily 
representative. 

To assess the comparability and quality of inventories from Annex I 
nations, we summarized the results of the Convention's 2009 reviews of 
inventories from selected Annex I nations, the most recent reviews 
available. We did not independently assess the validity of data, 
assumptions, or methodologies underlying the inventories we reviewed. 
Though we identified some limitations with the inventory review 
process, we believe that reviews provide reasonable assessments of the 
comparability and quality of inventories from selected Annex I 
nations. For non-Annex I nations, we assessed whether the latest 
inventories from selected nations included estimates for all major 
greenhouse gases (carbon dioxide, methane, nitrous oxide, 
hydroflurocarbons, sulfur hexafluoride, and perfluorocarbons), for all 
sectors (energy, industrial processes, solvent and other product use, 
agriculture, land-use change and forestry, and waste) and various 
years, and checked for inclusion of key inventory characteristics, 
including descriptions of uncertainty and quality assurance and 
quality control measures, adequate documentation to support estimates, 
a comparable format, and analysis to identify emissions from key 
sources. Though inventory guidelines do not call for all of these from 
non-Annex I nations, we believe they are indicative of the quality and 
comparability of inventories. We did not independently assess 
emissions estimates from non-Annex I nations. We used the quality 
principles agreed to by Parties for Annex I nations--transparency, 
consistency, comparability, completeness, and accuracy--as the basis 
of our review of all inventories and in our discussions with experts. 
[Footnote 55] We also provide information on the reported uncertainty 
of emissions estimates, a more objective indicator of their precision, 
and on the timeliness of inventory submissions. To identify barriers 
to improving inventories, we reviewed relevant literature, including 
national communications from the seven selected non-Annex I nations, 
and summarized the views of our expert group. 

To address the second objective, we summarized the results of semi- 
structured interviews with experts and Secretariat officials. We 
reviewed Convention documentation about the inventory review process, 
including Compliance Committee and Subsidiary Body for Implementation 
reports. 

To address all three objectives, we summarized findings in the 
literature and the results of semi-structured interviews with experts. 
First, we identified 285 experts from our review of the literature and 
recommendations from U.S. and international government officials and 
researchers. From this list, we selected 15 experts based on (1) the 
relevance and extent of their publications, (2) recommendations from 
others in the inventory field, and (3) the extent to which experts 
served in the Consultative Group of Experts (a group assembled by the 
Convention to assist non-Annex I nations improve their national 
communications), as lead reviewers in the Convention's inventory 
review process, or were members of the National Research Council's 
committee on verifying greenhouse gas emissions. Finally, to ensure 
coverage and range of perspectives, we selected experts who had 
information about key sectors, like the agriculture and energy 
sectors, came from both Annex I and non-Annex I nations and key 
institutions, and provided perspectives from both those who were 
involved in the inventory review process and from those not directly 
involved in preparing or reviewing inventories. Appendix II lists the 
experts we interviewed, which included agency and international 
officials, researchers, and members of inventory review teams. We 
conducted a content analysis to assess experts' responses and grouped 
responses into overall themes. The views expressed by experts do not 
necessarily represent the views of GAO. Not all of the experts 
provided their views on all issues. We identify the number of experts 
providing views where relevant. 

During the course of our review, we interviewed officials, 
researchers, and members of inventory review teams from State, EPA, 
and the Department of Energy in Washington, D.C.; the Convention 
Secretariat's office in Bonn, Germany; and from various think tanks, 
nongovernmental organizations, and international organizations. 

We conducted this performance audit from September 2009 to July 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: List of Experts: 

Scott Barrett, Columbia University: 

Clare Breidenich, Independent Consultant: 

Jane Ellis, Organisation for Economic Co-operation and Development: 

Thelma Krug, Inter American Institute for Global Change Research, 
Brazil: 

Bill Irving, Environmental Protection Agency: 

Bo Lim, United Nations Development Programme: 

Gregg Marland, Oak Ridge National Laboratory: 

Julia Martinez, Climate Change Program, Mexico: 

Sebastian Oberthür, Vrije University Brussels: 

Riitta Pipatti, Head of the Greenhouse Gas Inventory Unit at 
Statistics Finland: 

Helen Plume, Ministry for the Environment, New Zealand: 

Michael Prather, University of California, Irvine: 

Kristin Rypdal, Office of the Auditor General of Norway: 

Karen Treanton, International Energy Agency: 

David Victor, University of California-San Diego: 

[End of section] 

Appendix III: Comments from the Department of State: 

United States Department of State: 
Chief Financial Officer: 
Washington, D.C. 20520: 

July 20, 2010: 
	
Ms. Jacquelyn Williams-Bridgers: 
Managing Director: 
International Affairs and Trade: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548-0001: 
	
Dear Ms. Williams-Bridgers: 

We appreciate the opportunity to review your draft report, "Climate 
Change: The Quality, Comparability, and Review of Emissions 
Inventories Vary Between Developed and Developing Nations," GAO Job 
Code 361122. 

The enclosed Department of State comments are provided for 
incorporation with this letter as an appendix to the final report. 

If you have any questions concerning this response, please contact 
Kate Larsen, Foreign Affairs Officer, Bureau of Oceans, International 
Environmental and Scientific Affairs at (202) 647-1863. 

Sincerely, 

Signed by: 

James L. Millette: 

cc: 
GAO — Mike Hix: 
OES — Dr. Kerri-Ann Jones: 
State/OIG — Tracy Burnett: 

[End of letter] 

Department of State Comments on GAO Draft Report: 

Climate Change: The Quality, Comparability, and Review of Emissions 
Inventories Vary Between Developed and Developing Nations (GAO-10-818, 
GAO Code 361122): 

Thank you for the opportunity to comment on your draft report entitled 
"Climate Change: The Quality, Comparability, and Review of Emissions 
Inventories Vary Between Developed and Developing Nations." The 
Department of State recognizes the central importance of accurate 
greenhouse gas emissions inventories as a first step to addressing the 
problem of climate change and has long been a strong supporter of 
improving the quality of inventories and enhancing international 
review. 

The Department of State endorses the main findings and conclusions of 
the GAO report. We believe that GAO's assessment of the current state 
of inventory reporting and review for both developed and developing 
countries and the implications for the effectiveness of future 
agreements under the UNFCCC is both accurate and balanced. 

The Department of State agrees fully with the recommendations 
contained in the report and has been working with our international 
partners in the negotiations and through bilateral and multilateral 
partnerships to support and promote improved inventory reporting and 
review. The Department of State will continue to encourage non-Annex I 
Parties, especially the major-emitting economies, to submit regular, 
comprehensive and comparable national emissions inventories and will 
work through the UNFCCC process to ensure that such inventories 
undergo a process of international consultation and analysis, as 
agreed in the Copenhagen Accord. 

The Department of State also agrees that there is a need to ensure an 
effective and efficient inventory review process, including through 
the exploration of strengthening quality assurance to ensure 
consistency and a high quality of inventory reviews. Providing the 
necessary transparency on greenhouse gas emissions and efforts to 
control them is a fundamental objective of the Department of State in 
any future international agreement under the UNFCCC. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

John B. Stephenson, (202) 512-3841 or stephensonj@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Michael Hix (Assistant 
Director), Russell Burnett, Colleen Candrl, Kendall Childers, Quindi 
Franco, Cindy Gilbert, Jack Hufnagle, Michael Kendix, Thomas Melito, 
Kim Raheb, Ben Shouse, Jeanette Soares, Kiki Theodoropoulos, Rajneesh 
Verma, and Loren Yager made key contributions to this report. 

[End of section] 

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Allowances in a Cap-and-Trade Program. [hyperlink, 
http://www.gao.gov/products/GAO-10-377]. Washington, D.C.: February 
24, 2010. 

Climate Change Policy: Preliminary Observations on Options for 
Distributing Emissions Allowances and Revenue under a Cap-and-Trade 
Program. [hyperlink, http://www.gao.gov/products/GAO-09-950T]. 
Washington, D.C.: August 4, 2009. 

Climate Change Trade Measures: Estimating Industry Effects. 
[hyperlink, http://www.gao.gov/products/GAO-09-875T]. Washington, 
D.C.: July 8, 2009. 

Climate Change Trade Measures: Considerations for U.S. Policy Makers. 
[hyperlink, http://www.gao.gov/products/GAO-09-724R]. Washington, 
D.C.: July 8, 2009. 

Climate Change: Observations on the Potential Role of Carbon Offsets 
in Climate Change Legislation. [hyperlink, 
http://www.gao.gov/products/GAO-09-456T]. Washington, D.C.: March 5, 
2009. 

Climate Change Science: High Quality Greenhouse Gas Emissions Data are 
a Cornerstone of Programs to Address Climate Change. [hyperlink, 
http://www.gao.gov/products/GAO-09-423T]. Washington, D.C.: February 
24, 2009. 

International Climate Change Programs: Lessons Learned from the 
European Union's Emissions Trading Scheme and the Kyoto Protocol's 
Clean Development Mechanism. [hyperlink, 
http://www.gao.gov/products/GAO-09-151]. Washington, D.C.: November 
18, 2008. 

Carbon Offsets: The U.S. Voluntary Market is Growing, but Quality 
Assurance Poses Challenges for Market Participants. [hyperlink, 
http://www.gao.gov/products/GAO-08-1048]. Washington, D.C.: August 29, 
2008. 

Climate Change: Expert Opinion on the Economics of Policy Options to 
Address Climate Change. [hyperlink, 
http://www.gao.gov/products/GAO-08-605]. Washington, D.C.: May 9, 2008. 

International Energy: International Forums Contribute to Energy 
Cooperation within Constraints. [hyperlink, 
http://www.gao.gov/products/GAO-07-170]. Washington, D.C.: December 
19, 2006. 

Climate Change: Selected Nations' Reports on Greenhouse Gas Emissions 
Varied in Their Adherence to Standards. [hyperlink, 
http://www.gao.gov/products/GAO-04-98]. Washington, D.C.: December 23, 
2003. 

Climate Change: Information on Three Air Pollutants' Climate Effects 
and Emissions Trends. [hyperlink, 
http://www.gao.gov/products/GAO-03-25]. Washington, D.C.: April 28, 
2003. 

International Environment: Expert's Observations on Enhancing 
Compliance With a Climate Change Agreement. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-99-248]. Washington, D.C.: August 
23, 1999. 

International Environment: Literature on the Effectiveness of 
International Environmental Agreements. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-99-148]. Washington, D.C.: May, 
1999. 

Global Warming: Difficulties Assessing Countries' Progress Stabilizing 
Emissions of Greenhouse Gases. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-96-188]. Washington, D.C.: 
September 4, 1996. 

[End of section] 

Footnotes: 

[1] The Convention's objective is to stabilize greenhouse gas 
concentrations in the atmosphere at a level that would prevent 
dangerous man-made interference with the climate system within a time 
frame sufficient to allow ecosystems to adapt naturally to climate 
change, to ensure that food production is not threatened, and to 
enable economic development to proceed in a sustainable manner. The 
five other gases are methane, nitrous oxide, and three synthetic 
gases--hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. 

[2] Under the Kyoto Protocol, each nation with a binding emissions 
target has a specified greenhouse gas emission limitation or reduction 
commitment. 

[3] While the United States is a Party to the Convention and signed 
the Kyoto Protocol in 1998, it is not bound by the protocol's terms 
because it has not been ratified by the Senate. 

[4] Human activities can cause the emission of greenhouse gases as 
well as their removal from the atmosphere. For example, activities 
that promote the growth of forests can lead to the removal of carbon 
dioxide from the atmosphere. Such removals are also called sinks. In 
this report, we use the term greenhouse gas emissions to refer to both 
emissions and removals unless otherwise noted. 

[5] When the Convention and its annexes were agreed to in 1992, Annex 
I included all members of the Organization for Economic Cooperation 
and Development at that time, Russia, Baltic nations, and several 
Central and Eastern European nations. Annex I was subsequently amended 
and, in 1998, several other Central and Eastern European nations, as 
well as Luxembourg and Liechtenstein, were added. Although Kazakhstan 
is not listed in Annex I of the Convention, it has expressed its 
intent to be bound by the Convention's reporting requirements for 
Annex I nations and began submitting inventories in 2009. 
Additionally, in December 2009, the Parties agreed to add Malta to the 
list of Annex I nations. This amendment will go into effect 6 months 
after the Convention Secretariat's communication to the Parties about 
the amendment's adoption. 

[6] The IPCC is a United Nations organization that, among other 
things, assesses the economic, scientific, and technical aspects of 
climate change. 

[7] Our prior report looked at inventories from Germany, Japan, the 
United Kingdom, and the United States among Annex I nations, and from 
China, India, and Mexico among non-Annex I nations. GAO, Climate 
Change: Selected Nations' Reports on Greenhouse Gas Emissions Varied 
in Their Adherence to Standards, [hyperlink, 
http://www.gao.gov/products/GAO-04-98] (Washington, D.C.: Dec. 23, 
2003). 

[8] See World Resources Institute, Climate Analysis Indicators Tool 
(CAIT) version 7.0, [hyperlink, http://cait.wri.org] (Washington, 
D.C., accessed May 25, 2010) and estimates from the Emission Database 
for Global Atmospheric Research in International Energy Agency (IEA), 
CO2 Emissions from Fuel Combustion, 2009 Edition (Paris, France, 2009). 

[9] Fossil-fuel related emissions are the largest contributor to 
global emissions, representing about two-thirds of global emissions in 
2005. The Energy Information Administration is a statistical agency 
within the Department of Energy that collects, analyzes and 
disseminates independent information on energy issues. Energy 
Information Administration, International Energy Statistics Database, 
[hyperlink, www.eia.doe.gov/emeu/international] (Washington, D.C., 
accessed May 11, 2010) and International Energy Outlook 2010, DOE/EIA-
0484 (Washington, D.C., May 2010). 

[10] EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990- 
2008, EPA-430-R-10-006, [hyperlink, 
http://epa.gov/climatechange/emissions/usgginventory.html] 
(Washington, D.C., Apr. 15, 2010). 

[11] We report estimates of emissions not related to land use because 
of the lack of comparable data on land use emissions for many nations 
for many years. World Resources Institute, CAIT version 7.0. 

[12] Because greenhouse gases differ in their potential to contribute 
to climate change, each gas is assigned a unique weight, called a 
global warming potential, based on its heat absorbing ability relative 
to carbon dioxide over a fixed period. This weighting provides a way 
to convert emissions of various greenhouse gases into a common 
measure, called carbon dioxide equivalent, which is used throughout 
this report. 

[13] The Secretariat is also funded by certain fees, which generated 
nearly $77 million from 2008 to 2009. 

[14] Various natural processes also emit greenhouse gases, such as 
forest fires and biological emission of methane from wetlands. Though 
differentiating emissions from human activities versus natural 
emissions can pose challenges, inventories under the Convention 
generally include emissions from human activities. 

[15] Three IPCC guidelines are currently being used, each addressing 
different aspects of inventories: Revised 1996 IPCC Guidelines for 
National Greenhouse Gas Inventories, Good Practice Guidance and 
Uncertainty Management in National Greenhouse Gas Inventories, and 
Good Practice Guidance for Land Use, Land-Use Change and Forestry. The 
IPCC has recently updated its general inventory guidelines, but the 
Parties have not yet agreed to start using these updated guidelines 
(2006 IPCC Guidelines for National Greenhouse Gas Inventories). 

[16] Some nations are collecting more detailed information on 
emissions at major facilities. In the United States, the EPA recently 
issued a rule establishing mandatory greenhouse gas reporting 
requirements for owners and operators of certain facilities that 
directly emit greenhouse gases as well as for certain fossil fuel 
suppliers and industrial greenhouse gas suppliers. The first reports 
are due in 2011. In addition, about 10,500 electric power and 
industrial installations across 27 European nations have been 
calculating and reporting greenhouse gas emissions under the European 
Union Emission Trading System. Most of these nations indicated they 
have used this detailed emissions information in developing their 2010 
inventories. 

[17] The Convention, Guidelines for the Preparation of National 
Communications by Parties Included In Annex I to the Convention, Part 
I: UNFCCC Reporting Guidelines on Annual Inventories, 
FCCC/SBSTA/2006/9 (Bonn, Germany, Aug. 18, 2006). 

[18] See [hyperlink, 
http://unfccc.int/national_reports/annex_i_ghg_inventories/national_inve
ntories_submissions/items/5270.php]. 

[19] Five Annex I nations with economies in transition--Bulgaria, 
Hungary, Poland, Romania, and Slovenia--are allowed to use other years 
as baselines. 

[20] In its 2009 inventory, Germany used updated guidance and emission 
factors to estimate emissions from agriculture, but it did not justify 
the changes, as the Parties have agreed to do. For 2006 emissions, the 
2009 changes to methodology for agriculture reduced emissions by about 
1.2 percent of the national total. The 2010 revisions have essentially 
reversed that. 

[21] The 2010 U.S. inventory submission includes updated carbon 
content assumptions. 

[22] EPA officials said they will include updated figures for the 2011 
inventory submission. 

[23] This is the statistical meaning of uncertainty. According to the 
IPCC, the term is sometimes used more generally and imprecisely when 
referring to greenhouse gas inventories--see IPCC, IPCC Good Practice 
Guidance and Uncertainty Management in National Greenhouse Gas 
Inventories, p. A3.19 (Geneva, 2000). An uncertainty percentage is 
often given as "plus or minus," meaning that the actual value could be 
either above or below the estimate by that percentage. Ranges reported 
here are for the 95 percent confidence interval. 

[24] National Research Council, Verifying Greenhouse Gas Emissions: 
Methods to Support International Climate Agreements (Washington, D.C., 
National Academies Press, 2010). 

[25] Of all 153 non-Annex I nations, only 24 have submitted more than 
their first inventories. 

[26] Brazil and Indonesia estimated annual emissions for 1990 through 
1994. These inventories were included in nations' national 
communications submitted on the following dates: Brazil, December 
2004; China, December 2004; India, June 2004; Indonesia, October 1999; 
Malaysia, August 2000; Mexico, December 2009; and South Korea, 
December 2003. 

[27] IEA, CO2 Emissions from Fuel Combustion, 2009 Edition. 

[28] Mexico's quantitative uncertainty analysis was a part of its 
third National Communication, but not in the fourth National 
Communication. 

[29] Unlike for Annex I nations, the reporting guidelines only 
encourage non-Annex I nations to use a common format. 

[30] Mexico's key source analysis was a part of its third National 
Communication. 

[31] Gregg, Jay S.; Andres, Robert J.; and Marland, Gregg, "China: 
Emissions Pattern of the World Leader in Carbon Dioxide Emissions from 
Fossil Fuel Consumption and Cement Production," Geophysical Research 
Letters, vol. 35 (2008). 

[32] IEA, CO2 Emissions from Fuel Combustion, 2009 Edition, I.5. 

[33] Emissions for selected non-Annex I nations are from World 
Resources Institute, and from inventories submitted to the Secretariat 
for Canada, Germany, Japan, and Russia. 

[34] National Research Council, Verifying Greenhouse Gas Emissions, 6. 

[35] Some of the experts we interviewed did not provide views on 
barriers to improving inventories. Twelve experts provided the views 
discussed in this section. 

[36] The committee recommended the production of global land-use and 
land cover maps every 2 years and the development of a research 
program to improve methods for estimating agriculture, forestry, and 
land-use emissions. See National Research Council, Verifying 
Greenhouse Gas Emissions, 9. 

[37] Belarus, Turkey, and the United States do not have binding 
emissions targets or commitments under the Kyoto Protocol, though all 
are included in the Convention's Annex I. 

[38] The Kyoto Protocol established three mechanisms that provide cost-
effective ways for industrial nations to reduce their emissions. 
Emissions trading allows nations with emissions lower than their Kyoto 
targets to sell excess allowances to nations with emissions exceeding 
their targets. The Clean Development Mechanism and Joint 
Implementation allow nations with binding targets to implement 
projects that reduce or avoid emissions--such as the construction of 
renewable energy infrastructure--in developing nations that do not 
have binding emissions targets or industrialized nations respectively. 
These projects can earn credits, which industrial nation sponsors can 
use for compliance with their Kyoto targets. 

[39] When inventory review teams find that a Kyoto Protocol Annex I 
nation's inventory is incomplete or not consistent with applicable 
guidelines, they may suggest "adjustments" to correct the shortcoming. 
Nations are ineligible if, for example, their inventory (1) is not 
submitted within 6 weeks of the due date, (2) omits an estimate for 
certain categories of emissions, or (3) annual adjusted emissions for 
a single year in the commitment period exceeds reported emissions by 
more than 7 percent. See, Guidelines for the Preparation of the 
Information Required Under Article 7 of the Kyoto Protocol, 
FCCC/KP/CMP/2005/8 Add.2, Decision 15/CMP.1, par 3. 

[40] National Research Council, Verifying Greenhouse Gas Emissions, 6. 

[41] Some of the experts did not provide views on the strengths and 
limitations of the inventory review process. Twelve experts provided 
the views discussed in this section. 

[42] Because the authority for the review teams to make adjustments is 
provided by the Kyoto Protocol, the review teams cannot adjust 
estimates for Belarus, Turkey, or the United States, the Annex I 
nations that do not have Kyoto Protocol commitments. 

[43] The Convention, Report of the Review of the Initial Report of 
Greece, FCCC/IRR/2007/GRC (Bonn, Germany, Dec. 28, 2007). 

[44] France, "Submission by France on Behalf of The European Community 
and Its Member States," Experiences With and Lessons Learned From the 
Review of Initial Reports Under the Kyoto Protocol, Including 
Recommendations for Improvements, FCCC/SBI/2008/MISC.7 (Bonn, Germany, 
2008) 7. 

[45] France, Experiences With and Lessons Learned From the Review of 
Initial Reports, 7. 

[46] Though neither the Secretariat nor review teams are required to 
follow them, we examined the standards, descriptions or guidelines of 
the review processes in the following: (1) International Standard 
Organization (ISO) guidance for verifying greenhouse gas assertions 
(ISO, Greenhouse gases--Part 3: Specification with Guidance for the 
Validation and Verification of Greenhouse Gas Assertions, ISO 14064-3 
(Geneva, Switzerland, 2006)), (2) the study process used by the 
National Academies, (3) Government Auditing Standards (GAO, Government 
Auditing Standards July 2007 Revision, GAO-07-731G (Washington, D.C.: 
July, 2007).), and (4) the Institute for Internal Auditors standards 
(The Institute of internal Auditors, International Professional 
Practices Framework (Altamonte Springs, Florida, January 2009)). 

[47] IPCC, "Quality Assurance and Quality Control," Good Practice 
Guidance and Uncertainty Management in National Greenhouse Gas 
Inventories (2000). 

[48] The Framework Convention's Subsidiary Body for Implementation 
assists the Parties in assessing and reviewing the effective 
implementation of the Convention, and the Subsidiary Body for 
Scientific and Technological Advice provides the Parties with 
information and advice on scientific and technological matters, 
including matters that relate to inventories. 

[49] The Convention, Sixth Compilation and Synthesis of Initial 
National Communications from Parties Not Included in Annex I to the 
Convention, FCCC/SBI/2005/18 (Bonn, Germany, 2005). 

[50] Some of the experts we interviewed did not provide views on the 
implications for international agreements because, for example, they 
felt they were not experts in these issues. Eleven experts provided 
views discussed in this section. 

[51] Inventories that Annex I Parties with Kyoto commitments submitted 
in 2010, which are currently being reviewed, are the first to include 
emissions estimates for years included in the Kyoto Protocol's 2008- 
2012 commitment period, though inventories to establish baseline 
emissions have already been reviewed. 

[52] Under the Kyoto Protocol, nations can only use certain emissions 
from land-use change and forestry to meet the Protocol's targets. 

[53] For example, IEA publishes yearly estimates of carbon dioxide 
emissions from the combustion of fossil fuels, the most recent of 
which includes estimates from 1971 to 2007 for 140 nations. In 
addition, the Emission Database for Global Atmospheric Research, 
developed by the European Commission's Joint Research Centre and the 
Netherlands Environmental Assessment Agency, estimates other sources 
of carbon dioxide and other greenhouse gases emissions. See IEA, CO2 
Emissions from Fuel Combustion, 2009 Edition and [hyperlink, 
http://edgar.jrc.ec.europa.eu/]. 

[54] Based on more recent data, Malaysia is no longer one of the seven 
highest emitting non-Annex I nations. 

[55] The Convention, Guidelines for the Preparation of National 
Communications by Parties Included in Annex I to the Convention, Part 
I: UNFCCC Reporting Guidelines on Annual Inventories, 
FCCC/SBSTA/2006/9 (Bonn, Germany, Aug. 18, 2006). 

[End of section] 

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