Q.According to the Exhibit 1 (3) of the Guidelines, “While air could include greenhouse gases (GHG), specific requirements for environmental and social considerations on this issue are to be made based on the Common Approaches.” What provisions exist in the Common Approaches? Let us also know about the state of standards of international financial institutions used as benchmarks.

(1) Common Approaches
GHG is referred to in the Common Approaches as examples of “environmental impacts” of environmental and social impacts to be specified in the passage “generation of significant air emissions, including greenhouse gas emissions” (IV CLASSIFICATION, Paragraph 10). However, our understanding is that this does not require additional measures with respect to environmental reviews, monitoring and information disclosure.
On the other hand, the Common Approaches set forth that Adherents (Members and non-Members adhering to the Common Approaches) shall continue to build a body of experience on the application of the Common Approaches through regular reporting and exchanges of information, and as part of this proposition, the Common Approaches requires reporting the following on GHG to the OECD. (VIII REPORTING AND MONITORING OF THE RECOMMENDATION, paragraph 46)
• The estimated annual greenhouse gas emissions from all fossil-fuel power plant projects.
• The estimated annual greenhouse gas emissions from other projects, where such emissions are projected to be in excess of 25 000 tonnes CO2-equivalent annually and where the applicant or project sponsor has provided the Adherents with the necessary information, e.g. via an ESIA report.
The Common Approaches further stipulate that where relevant and feasible, Adherents shall try to obtain and to report the estimated annual direct and indirect greenhouse gas emissions (Scope I and Scope II respectively) in CO2-equivalent and/or the estimated annual direct greenhouse gas emissions (Scope 1) by carbon intensity for greenhouse gases to be generated during the operations phase of the project. (VIII REPORTING AND MONITORING OF THE RECOMMENDATION, paragraph 46).
The Common Approaches also listed support for thermal power plants as one of the issues that requires further consideration, and this will go further based on reporting of any actions taken to avoid, minimize and/or offset CO2 emissions for all thermal power projects exceeding 700g/kWh emission intensity (VIII REPORTING AND MONITORING OF THE RECOMMENDATION, paragraph 47).
(2) International Standards used as benchmarks
IFC Performance Standard 3, which is one of the international standards used as a benchmark, makes the following requirements for project sponsors with respect to GHG emissions.
• Client will consider alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during the design and operation of the project (Paragraph 7).
• For projects that are expected to or currently produce more than 25,000 tonnes of CO2-equivalent annually, the client will quantify direct emissions from the facilities owned or controlled within the physical project boundary, as well as indirect emissions associated with the off-site production of energy used by the project. Quantification of GHG emissions will be conducted by the client annually in accordance with internationally recognized methodologies and good practice.
Although the World Bank Safeguard Policies does not set forth requirements for GHG emissions, our understanding is that it is under consideration for revision in the similar manner as in IFC Performance Standards (Paragraph 8).
In addition, the World Bank Environmental and Social Standard 3 requires Borrowers to take the following actions.
• To consider alternatives and implement technically and financially feasible and cost-effective options to avoid or minimize project-related air emissions (including GHG) during the design, construction and operation of the project (Paragraph 15, footnote 12).
• As part of the environmental and social assessment of the project, to characterize and estimate sources of air pollution related to the project. This will include an estimate of gross GHG emissions resulting from the project, providing that such estimation is technically and financially feasible. For projects that have diverse and small sources of emissions (for example, community-driven development projects) or where emissions are not likely to be significant (for example, projects in education and social protection), GHG estimations will not be required (Paragraph 16).