Samoa, on behalf of the Alliance of Small Island States, is pleased to have this opportunity to
further elaborate on the AOSIS position on land use, land use change and forestry (LULUCF).
This submission builds on previous submissions and statements by AOSIS and its
spokespersons. It is necessary to also bear in mind that AOSIS believes that a draft decision on
this issue is premature, and should not be the basis for discussion in the context of the present
work program of the working group under the Subsidiary Body on Scientific and Technical
Advice.
AOSIS is of the view that any consideration of textual proposals on land use, land use change
and forestry should address at least the following elements:
1. definitional and accounting issues associated with Article 3.3 and 3.4 of the Kyoto Protocol
and their relationship to Annex I Assigned Amounts;
2. reporting and inventory requirements under Articles 5 and 7 of the Kyoto Protocol.
It is our belief that decisions on these elements should not be made separately as they are
inextricably linked.
This submission addresses these elements and is presented without prejudice to further
considerations based on an assessment of the data sets provided by Annex I Parties by August 1.
As stated above, it is our belief that the development of decision text is premature as we have yet
to review these data sets. Furthermore AOSIS considers that there is a need to discuss how these
elements may be linked to other issues covered by draft text on mechanisms and on compliance
with the Kyoto Protocol. Therefore the discussion below cannot be seen as exhaustive, but
rather is intended to assist the working group in its deliberation and the Secretariat in its
preparation for COP6.
AOSIS reserves the right to make further submissions after the group has thoroughly considered
the implications of the data sets submitted by Parties on August 1.
Definitional and Accounting Issues Associated with Article 3.3, Afforestation, Reforestation
and Deforestation and their Relationship to Annex I Assigned Amounts:
Direct Human Induced:
The term “direct human induced” in relation to Article 3.3 of the Kyoto Protocol should mean
any action directly carried out by humans that results in an activity referred to as afforestation,
reforestation and deforestation defined below. Such an action would not include human
activities that are not directly associated with afforestation and reforestation activities, for
instance, carbon fertilization, nitrogen deposition, and natural regeneration. For the purposes of
this definition, a human induced activity that leads to deforestation, whether intentionally or
otherwise would constitute a “direct human induced” activity. Such an activity could include
partial or complete land or forest cleaning by fire, pest outbreak, inundation of a forested area by
a dam, and forest loss due to salination.
Comment:
The difference in defining direct human induced for reforestation and deforestation is aimed at
erring on the side of caution as suggested by the IPCC in the Report on Land Use, Land Use
Change and Forestry.
Definition of a Forest:
A forest for the purpose of determining afforestation, reforestation and deforestation in relation
to Article 3.3, should be defined as an area of trees of no less than 0.5 ha in size. Such an area of
trees would be defined within the following biome categories: tropical forests, temperate forests,
boreal forests, tropical savannahs, temperate grasslands, deserts and semi-deserts, tundra,
wetlands.
Comment:
The biome categories should be defined by the COP/MOP as an international set of definitions,
with guidance from a technical panel of experts. The biome categories will also include a
determination of threshold levels for each biome category, most likely based on a canopy cover
definition.

Parties should not be given the opportunity to make their own definition on forests as this would
unduly overburden the accounting system and make determinations of verifiability cumbersome.
Afforestation:
Afforestation should be defined as the conversion of land (which has not had a forest on it for a
period of at least 50 years prior to 1990) to forested land. For the purposes of this definition
afforestation includes land containing immature forest trees which have grown as a result of a
direct human induced activity, so long as it can be shown that these young trees are intended to
grow to the threshold canopy cover according to the biome type.
Comment:
The inclusion of immature forests allows Parties to account for removals of greenhouse gases
(GHG) prior to the possible threshold definition of forests. Should these immature trees not
reach the threshold value for determining a forest under the biome definition, any accounting for
their GHG removals would be reversed and added to a Party’s assigned amount.
Reforestation:
Reforestation should be defined as the conversion to land that has supported forest within the
past 50 years, but was converted to non-forested land prior to 1990, to forested land. For the
purposes of this definition, reforestation includes land containing immature forest trees, which
have grown as a result of a direct human induced activity, so long as it can be shown that these
young trees are intended to grow to the threshold canopy cover according to the biome type.
Reforestation does not include regeneration or revegetation after harvesting.
– 5 –
Comment:
This definition ostensibly uses the land use change definition. The requirement that land must be
non-forest prior to 1990 overcomes the opportunities for Parties to clear an existing forest, place
the land briefly under another land use and then reforest it after 1990. As the IPCC has pointed
out in the Special Report on Land Use, Land Use Change and Forestry, under such a scenario a
Party would not have the emissions from the initial clearing of the forest accounted for, (except
for residue carbon soil emissions during the commitment period), due to the phraseology “carbon
stock changes during the commitment period”.
Deforestation:
Deforestation should be defined as the conversion of forested land to non-forested land. For the
purposes of this definition, deforestation includes land in the process of deforestation whereby
the land is likely to be cleared within a period of 50 years. For the purposes of this definition,
the clearing of a natural forest or thinning of a natural forest for the purposes of replanting with a
silvicultural forest, plantation or planted forest, by fire or any other direct human induced
activity, shall be deemed to be deforestation.
Comment:
As a means of creating an accounting balance between reforestation and deforestation, in relation
to the immature trees issue, deforestation should also be considered an incremental process and
need not be based on a threshold of total land use change.
Carbon Stocks Changes for Afforestation and Reforestation:
Carbon stock changes for the purposes of afforestation and reforestation should include both
above ground and below ground carbon. Any emissions due to the creation of an afforestation or
reforestation activity, for instance soil disturbance, shall be accounted for.
For the purpose of accounting for carbon removals from afforestation and reforestation, Parties
may chose to account for only above ground biomass carbon.
Comment:
The differential between emissions and removals is aimed at erring on the conservative side as
suggested by the IPCC in the Special Report on Land Use, Land Use Change and Forestry.
Carbon Stock Changes for Deforestation:
Carbon stock changes for the purposes of deforestation should include emissions from all
greenhouse gases listed in Annex A, whether these are from above ground, below ground
(including soil carbon) sources or from wetlands.


Comment:
For the purposes of determining deforestation all greenhouse gases should be included and
should be based on above ground, below ground and aquatic sources associated with wetlands.
Wood and Other Forest Products:
Carbon stock in wood and other forest products should not be counted as sinks under ARD
activities.
Comment:
Because the above definition of ARD activities does not include the harvest/regeneration cycle,
accounting should exclude wood or other forest products as sinks.
Consistency with Sustainable Development, Ecosystem Approach and Social, Cultural and
Community Rights:
Activities associated with afforestation, reforestation and deforestation shall be consistent with
and supportive of the principles of sustainable development, the ecosystem approach as defined
by the Conference of Parties to the Convention on Biological Diversity and the protection of
social, cultural and community rights.
Comment:
Management of forests for the purpose of carbon credits should be consistent with other
important values of forests.
Supplemental Information required for annual inventories of 3.3 Activities:
In accordance with Articles 5 & 7, the IPCC Guidelines should be revised to fully account for
ARD activities as defined above.
Comment:
AOSIS believes that the current IPCC Guidelines require further elaboration to fully account for
the revised definition of ARD activities as described above.
Definitional and Accounting Issues Associated with Article 3.4, additional human induced
activities and their Relationship to Annex I Assigned Amounts:
No Additional Activities:
AOSIS considers it inappropriate to include any additional activities (Art 3.4 activities) for the
purpose of adding to, or subtracting from, the assigned amounts for Parties included in Annex I
for the first commitment period. An assessment of ARD should be made in the middle of the
first commitment period as a means of giving guidance to the consideration of the possible
inclusion of additional human induced activities in the second commitment period. Such a
consideration shall be based on a review of commitments for the second commitment period.
Comment:
Based on the numerous accounting uncertainties associated with afforestation, reforestation and
deforestation, it is our belief that no additional activities should be included until there is an
adequate assessment of ARD activities during the first commitment period. Additional activities
may be considered for the second commitment period subject to a review of commitments by
Annex I Parties.
Biomass Fuel Definitional Issue:
Biomass fuel projects generally do not fall directly within the definition of afforestation,
reforestation and deforestation (Art 3.3) nor under additional activities (Art. 3.4). Subsequently,
we believe that biomass fuel projects should be considered to be renewable energy projects and
should be accounted for under this category. Due to the fact that they involve a land use activity,
approval of biomass energy projects should be consistent with and supportive of principles of
sustainable development and environmental and social protection (as stated earlier).
Comment:
Because biomass fuels are neither a source nor a sink, in general terms, they should primarily be
considered as energy projects even though they do involve a land use activity. Biomass fuels
should be accounted for, including issues associated with leakage and non-permanence, if the
biomass is destroyed before it becomes available as a fuel.
Definitional and Accounting Issues Associated with Article 3.7, additional human induced
activities and their Relationship to Annex I Assigned Amounts:
Land Use Change:
Land use change in the context of Art 3.7 should be defined as land subject to afforestation,
reforestation and deforestation as defined above for Art 3.3.
Comment:
This section should be consistent with the definition of ARD as defined above.