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Draft document: Experimental Ecosystem Accounting--Extended Deadline for Comment January 15, 2013

Draft document:
Cover note:
Comment template:
Posted on:13/11/2012
Deadline for comments:15/01/2013
Number of comments:56

Comments from the broad consultation
Posted onProvided byComments
07/02/2013United Kingdom / Natural Capital Committee EEA_UK2.pdf;   
23/01/2013Iran• In Paragraph 3.2 the boundary between ecosystem services/assets should be clearly defined. In this regard, it is recommended that the activities should be assessed in details, for their relationship with the ecosystem. • In Paragraph 4.2 on assessing the ecosystem assets, a proper, standard and applicable methodology should be determined for valuation of the assets.
21/01/2013Canada/ Environment Canada EEA_Canada_Env.pdf;   
21/01/2013Paulo Mibielli /Brazilian Society for Ecological Economics My comments are personal, not institutional. 1) It would be important to use more examples in the manual of real or hypothetical cases. Everything is in very abstract, because there are very few examples. The item 2.74 on page 28 says that there may be a trade-off between ecosystem services in the same area (standing forest versus forest lying?). This is not clear, but with an example it could be. 2) Another point that is not clear is the question of "where it ends the ecosystem service and begins the ecosystem benefit" (page 39 item 3.18 and following). It was not clear to me that distinction. Also the differential treatment given to agriculture (production via human action) versus extraction ("natural" production). 3) It would be important to make more clear the water issue. There are moments in the manual it seems that water is excluded because the abiotic services are excluded (p 45 item 3.39). But elsewhere it is said that the use of water is an ecosystem service (table 3.1 pag 44). Later (Table 3.4 pag 49) is said that the service is filtering and storage of water, which are not a use in itself but only enables the use. 4) Also on the water issue , I would strengthen in the manual the link between the account ecosystems with the water account. This point is not mentioned directly in the manual, but it is said that the most feasible, due to methodological and data offering, is to initiate account of ecosystem by the provision service for water supply (page 51 item 3.74). The water account is standard, which means, this is an account (theoretically) compulsory for all countries. Therefore to strengthen the link makes perfect sense. 5) Another link I would enhance is the storage of carbon (highlighted in section 3.75 of page 51) with the issue of climate change. The making of the accounting of carbon storage - which in theory all countries should be doing-is making of the accounting for an ecosystem service, so in a sense, is the beginning of an ecosystem account.
17/01/2013Statistics CanadaThe document is in general very clear. The discussion is fairly academic, however, and as a result it can be difficult to imagine how these guidelines could be used in a practical application. It would be thus desirable if examples of work could be presented alongside the technical discussion so that readers could see actual policy questions that had been addressed with these techniques. A few of these, showing a policy question, the data gaps, the approach taken and how this has been generalised for broader application in the SEEA could be referenced as examples in the discussion. Another modification that may assist in understanding would be the addition of units of measure to the sample tables. This would provide a clearer link to the kinds of data that would be presented. In table 2.1 for example, would we be talking about Watts of sunlight, or cubic metres of flood water protection, or some other type of measure? Would table 2.3 be in monetary terms? It''''s not always clear what we would put in the tables. On the topic of "physical units of measure" some further discussion may be warranted. In 2.103, we see a distinction expressed between them (i.e. "physical and non-monetary") whereas in 3.2 we see that physical is non-monetary. Would something like number of visits to a national park (suggested in 3.48) be considered a physical unit of measure? The term does not seem appropriate here.
   EEA_Canada.pdf;   
16/01/2013University of Nottingham and on behalf of EEA/ Roy Haines-Young EEA_CICES.pdf;    CICES_Report.pdf;    CICES_V43.xls;   
16/01/2013China I think the SEEA experimental ecosystem accounting covers most important contents of ecosystem accounting, but it still need further revision and improvement, especially the definition of ecosystem assets and ecosystem service, the measurement method of physical and monetary ecosystem services.
16/01/2013Czech Republic/Charles University Environment CenterConcerning the structure of the document, we would recommend changing the order of Chapter 3 and Chapter 4. Chapter 4 should precede Chapter 3, as ecosystem assets are prerequisite for ecosystem service flows. Therefore, first it should be accounted for ecosystem assets and consequently for ecosystem services derived from these assets. We miss a reference to Land and Ecosystem Accounting (LEAC), which has been promoted by European Environment Agency and serves as a basic framework for land cover/land use/ecosystem accounting. Furthermore, we miss stronger reference to Millennium Ecosystem Assessment (MA) which developed a basic classification of ecosystem services and streamlined it into decision-making.
  Chapter 3: We would recommend using „biophysical" instead of „physical", as ecosystem services are result of biophysical interactions rather than purely physical forces. 3.3: We recommend using "in bundles" instead of "in tandem", which reflects standard terminology used in ES studies. 3.3: "Ecosystem accounting enables evaluation of trade-offs": we recommend reformulate to: Ecosystem accounting is a prerequisite for the evaluation of trade-offs", as trade-offs are examined by consequent analysis (statistics, modelling) and not by accounting per se. 3.27: Storage of ecosystem services is somehow problematic concept. Ecosystem service is delivered by natural processes as benefits to final users. Therefore, changes in stock or "storage" or biophysical structures supporting the provision of ES are not relevant for ecosystem service accounting. However, they should be included in "ecosystem assets" accounting. The EEAs should account for net benefit delivered by ecosystems in an accounting period, as "storage" of ecosystem services would excessively complicate account structure. Chapter 4: Land and Ecosystem Accounting(LEAC) should be explicitly incorporated, starting with matrices/tables for Land Cover Flows (LCF), followed by water, carbon and biodiversity tables. 4.117: Please include also "Red List Index" into the list of main biodiversity indices (see Vackár, D., ten Brink, B., Loh, J., Baillie J.E.M., Reyers, B., 2012. Review of multispecies indices formonitoring human impacts on biodiversity. Ecological Indicators 17: 58-67, for reference).
15/01/2013European Commission, Directorate General Environment EEA_DGE.pdf;   
15/01/2013Economic and Social Commission for Asia and the Pacific (ESCAP) EEA_ESCAP.pdf;   
15/01/2013European Environment AgencyThe SEEA Part 2 draft fulfils rather well the mandate given by the UNCEEA to the Secretariat, the World Bank and the European Environment Agency and now allows for further steps to be taken across the world on further experimentation. This achievement is the result of a genuine collective effort of the three above mentioned organisations, supported by a group of experts which met in Copenhagen, London and Melbourne and also contributed through drafting inputs on several issues, as well as steering by the Editorial Board put in place by the UNCEEA.
 EEA_EEA.pdf;   
15/01/2013United KingdomDefra and the ONS welcome the release of the consultation draft of the SEEA Experimental Ecosystem Accounting report. We think this is a very significant step forward in supporting the development of ecosystem accounts that follow an agreed set of principles and that explicitly relate to the SEEA Central Framework for environmental accounts. It is important for us that the report covers principles for ecosystem valuation alongside principles for measuring flows and assets in physical terms. We see valuation (in addition to physical measurement) of stocks and flows as an essential part of an ecosystem accounting approach. A monetary metric helps in assessing trade-offs and places the economic value of ecosystems on a comparable basis with conventional accounting measures. We recognise that valuation in itself may not be sufficient when it comes to addressing questions of sustainability. Among other things, integrated ecosystem accounts would be the ideal framework to investigate unacceptable depletion or damage in relation to environmental limits/thresholds. We still have general concerns about readability and the amount of repetition. Examples are given in the specific comments. We agree the need for a glossary of terms.
 EEA_UK.pdf;   
15/01/2013JordanDepartment of Statistics expresses its great thanks to the team who was behind introducing this document in this way, to serve both statisticians and environmentalists. At the same time, it seems that more time and work are still remaining in term of implementation the accounts. The document is written well, also the document structure is excellent and the material is adequately balanced.
  In respect to the scientific background of the ecosystems, it is not an easy assignment to be compiled and implemented. Therefore, and as an additional point, I would suggest and with highly appreciation to the complicated nature of the ecosystems, to execute a parallel process with this SEEA Experimental Ecosystem Accounting. This process is about putting a joint academic researches together with the practitioners of the Ecosystem accounts in NSO. Since it is a newly assignment and the effects of such output will be increasingly required by industrial developers, academic researches, policy makers, economists, environmentalists, socialists and the statisticians.
15/01/2013LithuaniaStatistics Lithuania appreciates the efforts put in developing the current consultation draft of the volume of Experimental ecosystem accounting. Whereas ecosystem accounting is still only at an experimental stage of development (A Common International Classification of Ecosystem Services (CICES) is under development, various concepts and measurement issues are work in progress), we consider that the document is well-structured and, in general, contains the most important elements related to ecosystem accounting. However, after consultation with colleagues from other institutions, we consider that the following comments could be useful: 3.2.3. Other measurement issues. A suggestion for this section would be to make it more clearly (in a more detailed manner) explained or located in another place in the structure. In its current place the section provides, for sure, correct but confusing bits of information, with almost no recommendations how to avoid or deal with the issues listed; thus, at the very beginning of the publication, leaving readers with confusing thoughts about “things impossible to manage better not even to start with...”. Moreover, some confusion could arise, for example, in case of abiotic and supporting services. In some cases there is a clear message that these services are not part of SEEA EEA, while in other parts (e.g. talking about CICES) these services are mentioned like the ones we should not forget. It is recommendable to try avoiding such uncertainties as much as possible (they make such a complex object as EA even more complicated) – to make the text more user-friendly, at least at the introductory stage. Despite the enormous efforts already made, there is still quite a lot of vagueness in the part explaining the linkages and connections during the analysis between ecosystem services information and information on economic units. A bit more clear, grounded and obvious presentation would be highly welcome. There are a lot of examples of good practice in the text; yet it would be extremely good to expand the current version (at least in some sections) with pieces of explanations, good examples, one or a few applicable straightforward decisions (of course, noting that these are just examples, and more possible choices are available), etc. how to deal with the difficulties or uncertainties presented in the text. This is one of the few issues of this draft – it is very informative but still leaves far too many questions unanswered and plenty of space to “build own ways forward”. A good example of a very supportive suggestion made is in, e.g., section Accounting for flows related to joint production of crops and other plants, line 3.24. One complicated problem, already mentioned in the draft, is that the system described could face serious implementation problems because of the need to convert or adjust ecosystem services accounting information to a common annual basis. Highly complex annual data sets, on the one hand, and extremely slow changes in some ecosystem services stocks, flows and quality, on the other, could easily become a headache for national statistical offices, both from financial and from data collection perspectives. It could be even more complicated than the former process of the incorporation of sustainable development indicators into the existing system. Thus, it would be helpful to have some more information about this issue, or some ideas (if there are any already) how to adapt EEA to existing statistical data collection systems (maybe even a possibility of establishment of every next year or every 5th year reporting period could be discussed already now?), or some more sections, like the one about the prioritisation of ecosystems and their services.
  Ecosystem accounting units – would be nice to have this concept a bit further developed, maybe it is more acceptable to use such terms, as local, regional, national level Ecosystem accounting units for this purpose?
15/01/2013FinlandI think that ecosystem accounts are of extreme importance for the future of environmental accounts. However, I would prefer a much more simple and straightforward definition of the statistical unit. Use of several different basic spatial units should be avoided. The criteria for the statistical units presented in beginning of ch. 2.3 are valid and relevant, but I have great difficulties in understanding the discussion in the later part of the chapter. I think that a more straightforward definition of the statistical unit would also clarify the relationship to economic classifications. Land use and ownership are ways to link the spatial units of ecosystem accounts to statistical units of economic statistics. However, we should also be able to link the ecosystem services and products produced by the spatial unit and the ecosystem services and products used for the building of the ecosystem capital of this spatial unit to the products and services of economic units. The proposed general structure of the accounts seems to be feasible and working. Unfortunately, the solution of the issue of statistical unit has some effects on the structure of the accounts in general. Pilot studies to test the delineation of statistical units are urgently needed.
  Sorry, I have no possibility to give detailed comments.
15/01/2013RussiaMost general comment: well structured and clear enough document. Certainly, the subject (ecosystem) is a very complex entity and in this draft it is considered mostly from its external sides, like properties and assets (used by society). Internal mechanisms of ecosystems, e.g. reproduction of assets and generation of benefits processes, are not directly studied. While "ecosystem processes" are mentioned on the fig.2.2, they are not defined. Notion "ecosystem asset" is defined (and can be measured) in multiple aspects (2.28). In one of them "ecosystem assets are considered in terms of expected ecosystem service flows. ... the capacity of an ecosystem asset to generate a basket of ecosystem services". This makes the measure of any ecosystem asset a potential concept with not clear enough meaning. Does this mean an ultimate level of "output" of ecosystem services? For many reasons it is difficult to consider ecosystem asset akin to productive capital because of its complex, synergetic (and significantly stochastic) nature. In this connection it looks like difficult to measure the "production capacity" (of ecosystem asset) in its usual meaning. Chapters 3-6, from my point of view, can be more or less equally referred to environmental accounting in general.
  It would be interesting to touch the question of how to treat ecosystems with a substantial share of artificial input. Actually some of them are more artificial than natural, like some tourist recreational zones. Not to mention big cities with their landscape gardening, surface and ground water regulation, etc. These ecosystems are so much transformed by a man that their "propensity to withstand change or to recover to their initial condition" or ecosystem resilience should be artificially supported. This support can be defined with a special set of economic activities (ecosystem reproduction activities).
14/01/2013United Nations Statistics DivisionUNSD welcomes and supports the development of the SEEA Experimental Ecosystem Accounting. The consultation draft reflects the state of the art on ecosystem accounts and provides a conceptual framework from which countries could start in the testing and experimentation of ecosystem accounting. The SEEA-Experimental Ecosystem Accounting remains work-in-progress in the sense that it would benefit from experience in countries experimenting on the application of the conceptual framework put forward. It provides a sound conceptual basis building on existing practices and scientific and economic knowledge.
 EEA_UNSD.pdf;   
14/01/2013Czech RepublicThe Czech Statistical Office appreciates all efforts and work done on the development of the SEEA Volume concerning Experimental Ecosystem Accounting. Thank you for the chance to comment this draft. Generally, we agree with the structure and style of the document but the CZSO is not involved in this topic and unfortunately we cannot provide any specific comments. We have sent this draft to a few bodies interested in ecosystem accounting, but we have not had any answer.
14/01/2013Qatar EEA_Qatar.pdf;   
14/01/2013MoroccoThank you for these efforts that build a real synergy and great cooperation within offices, and as Moroccan national account, we appreciate the opportunity to be a part and to contribute constructively to this version of draft. Generally, the article is well structured and wealthy. However, we suggest to add more tables for more organisation and clarity (Para 2.4: it will be more comprehensive if it will be formed in table)
08/01/2013India/VP ParameswaranThe following are my comments on the draft of SEEA Experimental Ecosystem Accounting: Para 2.8 Ecosystem degradation or ecosystem enhancement can also take place by natural processes. Is this aspect also covered here as the e.g. mentioned does not relate to natural processes? Para 2.11 It is mentioned that mineral and energy resources are the assets that do not interact as part of ecosystem processes. Release of gases in the underground mining areas do take place, Is this a process of interaction? What about the soil conditions around the mining areas? Para 2.59 Is there no possibility of duplication or mutual exclusiveness here? Is it allowed or how to deal with it? Para 2.60 I think there can be same type of two large scale natural features in two different EAUs. Para 2.70 Can''t the atmosphere (or quality of air) above one BSU be affected by the atmosphere or space above other neighbouring or even far away BSUs? In other words, characteristics of atmosphere above one particular BSU may have affected by characteristics of other neighbouring BSUs. For e.g. air above a clean and unpolluted area or BSU need not be clean if there are polluted BSUs nearby. Para 3.6 Does (iii) mean the ecosystem services that are generated from areas that are publicly owned or something more than that? What about the ecosystem services that are generated from economic assets that are privately and publicly owned and managed and which contribute to the production of public benefits? Para 3.20 Crop growth has a relation to nutrient cycling, abstraction of soil water, pollination etc. In other words, productivity is based on these factors. In such a case, will there be a significant difference between the ecosystem service equivalent to crop that is harvested (when the crop growth is not managed) and ecosystem services equivalent to combination of items (when the crop growth is cultivated)? Therefore, instead of complicating the matter one could go by the amount of crop that is harvested. Para 3.21(iii) What about the sub-national level assessment? Para 3.48 Cultural services are not only related to the people interacting with the ecosystem, but also the ecosystem attracting the people. For e.g. the number of people visiting a bird sanctuary also depends upon the number/variety of birds visiting the sanctuary. Table 3.3 Households also contribute for generation of ecosystem services. For e.g. independent houses having big gardens contribute both to regulating and cultural services. Even in the case of people residing in multi-storey apartments, terrace/kitchen gardens contribute to generation of ecosystem services. With more and more urbanisation taking place, such activities are in increasing trend.
08/01/2013Mexico EEA_Mexico.pdf;   
08/01/2013RomaniaWe do not have any comments regarding the Consultation on SEEA Experimental Ecosystem Accounting.
08/01/2013SwedenThank you for the chance to comment. We have sent out the document to a range of people interested in ecosystem accounting. They have not forwarded any comments through us, but perhaps you will receive their comments directly from them. We appreciate that you have written this first attempt to incorporate ecosystems into an accounting framework. Clearly, there lies much practical work ahead of us to make this area measurable in a harmonised statistical system. We intend to undertake work to see how we can include aspects of ecosystems into the accounts. For us the coupling to economic actors will be a major important issue. The SEEA for us has its strength in that it covers all the human activities in the economic production and consumption. We see that the management of land and water areas is not well reflected in the measuring practice today and we wish to add more information there. To set up a new data system based on grids with different properties as is suggested in Chapter 2.3 Units for ecosystem accounting, is not the way that we would want to go. Such information systems could be used as source data for identifying the most important aspects (what is referred to as "the statistical units are the entities about which information is sought") from an environmental accounting point of view. We would want to know how many square km of an ecosystem that is managed in a particular way. But an inventory of the properties of the land is a source of data rather than an account. As for the readability of the report, we were most interested in Chapter 3. Chapter 2 was more difficult to understand and could probably be condensed somewhat. It is difficult to understand what is intended by the term ecosystem – it is defined so that it could be life in a drop of water or a rainforest. From the Tables in Chapter 3 we got a feeling for the size that you intend to cover. Many of the research studies in this area cover much smaller systems and that will be a challenge to measure in a way that is comparable between larger regions or nations. The report seems to imply that biodiversity is a well-known concept with a clear measurement practice. To measure e.g. carbon or water we know the units and how to aggregate them. For biodiversity, there is a lot of data on species abundance, but not any clear recommendation on how to aggregate the information. In general, we expect to encounter difficulties when going from the local inventory to a national scale. As you note, this work will have to be conducted in close cooperation between many different kinds of organisations and experts. Let us hope that many countries will contribute by making pilot studies on which the practice can be built.
08/01/2013Eurostat EEA_Eurostat .pdf;   
08/01/2013France EEA_France.pdf;   
07/01/2013ColombiaEl DANE, después de revisar y analizar los documentos borrador del SEEA Revision: SEEA Experimental Ecosystem Accounting dentro del proceso de consulta global por parte de Naciones Unidas; del envío de comentarios al documento en su primera versión, y del establecimiento con satisfacción que los comentarios enviados por la entidad fueron integrados en la segunda versión del mismo, estamos de acuerdo en el desarrollo del SEEA Experimental Ecosystem Accounting. Esperamos seguir contribuyendo mediante la implementación de este Sistema en el ejercicio propio del avance de nuestras cuentas ambientales y en el marco del proyecto Wealth Accounting and Valuation of Environmental Services-WAVES del Banco Mundial, en el cual Colombia hace parte como país piloto y el DANE participa junto con otras instituciones en la estructura y aplicación de la cuenta de ecosistemas. Unofficial translation: The DANE, after revising and analyzing the "SEEA Revision: SEEA Experimental Ecosystem Accounting" draft documents, within the United Nation consultation process; of the submission of comments to the first draft, and establishing satisfactorily that the comments submitted by the entity were integrated to the second draft document, we agree the development of the SEE Experimental Ecosystem Accounting We look forward to continue contributing through the implementation of this system in the proper exercise of the progress of our environmental accounts and within the framework of the Wealth Accounting and Valuation of Environmental Services-WAVES project from the World Bank, in which Colombia takes part as pilot country and DANE participates with other institutions in the structure and application of the ecosystems account.
07/01/2013Spain/Spanish National Council for Scientific Research-Pablo Campos EEA_Spain.pdf;   
07/01/2013Singapore1. With regards to the importance of GIS application for SEEA reporting, it is recommended to include a section that focuses on GIS and its application, so as to provide a brief introduction of what GIS is about for non-GIS practitioners and to provide a pathway to show the critical role which GIS could play in SEEA reporting.
  1. Further explaining the concept of the Basic Spatial Unit (BSU) (Clause 2.43). A definition would be useful. For example: BSU is the "fundamental area unit having homogenous properties in the context of any required theme such as administrative responsibility or ownership (Green, 1994 )." 2. Elaborate on how GIS could be used to develop the ecosystem asset accounts (Clause 4.51). For example, GIS time series analysis can be used to visualize and supplement the analysis of time-factor activities mentioned in Clause 4.98.
07/01/2013BulgariaThe document SEEA Experimental Ecosystem Accounting (Consultation Draft) is a well structured and balanced material that marks the start in applying an integrated approach in this field. The material successfully provides a synthesis of current knowledge on ecosystem accounting and presents different measurement concepts. At the same time flexible research approaches are allowed. Central concepts in measuring ecosystems are clear and well described. We share the opinion that this document will play a key role in developing standards and in framing information sets in this area on national level. A specific challenge for the national statistical offices will be the ambitious aim to organize the information from a spatial perspective and to describe linkages between ecosystems and economic and other human activity on national level. Besides, as this is a new area of accounting, a large amount of information gaps exist on national level. Their filling-in will require both establishment of appropriate institutional co-ordination and applying spatially related analytical techniques.
  Due to resource limitations, when implementing ecosystem accounting at the national scale, it seems more appropriate to select initially a limited set of ecosystem services for inclusion in ecosystem accounting exercises.
04/01/2013BelarusNational Statistical Committee of the Republic of Belarus has no comments and suggestions to the draft within its competence.
  Owing to limited possibility of translation of documents from English into Russian in order to hold electronic consultations on developed projects, the National Statistical Committee of the Republic of Belarus kindly asks to send drafts of documents in Russian.
04/01/2013New Zealand/ Ecological Economics Research New Zealand (EERNZ)Thank you for the opportunity to review the ‘SEEA Experimental Ecosystem Accounting - Consultation Draft''. As Director of Ecological Economics Research New Zealand (EERNZ), more specifically as a researcher and practitioner in the field of Ecological Economics and Ecosystem Services, I am very familiar with the concepts presented in the draft consultation report. The ‘Core principles of Ecological Economics'' described on page 11 of the report reflect this field well. I am aware that this report is the result of many years work and consultations at the UN with internationally recognized Ecological Economists. I strongly support the proposition presented in this report. Guidance toward international consistency around how ecosystem services are described, classified and valued is extremely important. The proposed approach has the potential to guide the monitoring and reporting, while allowing flexibility for national policy making and local management of ecosystem processes. The Ecosystem Services paradigm and associated proposal for environment-economic accounting practices provides an opportunity to; (1) connect considerations at multiple scales: e.g. local, regional, national and global level; (2) develop a common language between ecology and economics, as well as between science and policy; (3) create integration and tradeoff scenarios of all relevant ecosystem benefits and; (4) consider the supply and demand of ecosystem services. An elaboration of point 4 is, for example, concerns the inelasticity of the supply of ecosystem services, which doesn''t respond to price signals but rather responds to slow changes in land use and ecosystem functioning. By comparison, the demand for ecosystem services may be more responsive to market based prices. In addition, the proposed framework allows for non-market valuation based approaches, which are crucial to accommodate certain ecosystem demand profiles, such as for cultural and spiritual values. ‘Uncertainty in valuation'' (page 100-101) is a science-policy challenge that needs to be understood and managed. Countries that succeed in doing this well will benefit from such understanding and pave the pathway toward ‘genuine progress'' and the realization of new value propositions. I strongly endorse the content and direction provided by the Consultation Draft. Please, don''t hesitate to contact me in the future for elaborations on this theme.
04/01/2013New Zealand/ Department of Conservation EEA_New_Zealand.pdf;   
04/01/2013New Zealand/ Statistics New ZealandStatistics NZ has little experience in this relatively new and highly challenging area so we have consulted with the leading central government agency working on ecosystem service valuation, the NZ Department of Conservation (DOC), and one of the countries leading research institutes, Ecological Economics Research New Zealand (EERNZ). I have attached both responses which broadly endorse, as Statistics NZ do, the approach being taken to build consensus and international agreement on definitions, standards, and methodology. Although DOC generally support the UNSD''''s approach, some of their technical feedback challenges the current proposals. We hope that this constructive feedback is helpful and look forward to working with you over the coming years to assist in the development of ecosystem accounting.
04/01/2013Malaysia1. In general, the structure of document are well written and organize. The examples and tables are useful and well elaborate. 2. We would like to suggest a structured tutorial for better understanding. 3. Since the Ecosystem Accounting has not been developed by DOSM, we are not able to provide specific qualified comments on this drafted methodology for ecosystem accounting.
   DOSM is very much interested in the efforts for systematic and intensive training on the methodology of developing the SEEA Experimental Ecosystem Accounting. Kindly include us if there is such training/workshop to be conducted in future.
03/01/2013Turkey EEA_Turkey.pdf;   
03/01/2013Netherlands EEA_Netherlands.pdf;   
02/01/2013Dominican RepublicIn general, the document contains the most important elements related to the account of ecosystem. Its structure is similar to the water account, which has been the only experience of integrated environmental and economic accounts held in the Dominican Republic, coordinated by several agencies. The topics and subtopics cover a variety of aspects, which as they progress in the development and implementation in some country, has undoubtedly may strengthen the system of integrated environmental and economic accounting.
31/12/2012Hong Kong, ChinaThe Consultation draft of SEEA has proposed a very useful framework about the measurement of ecosystem accounting. The classification of ecosystem services into provisioning services, regulating services and cultural services provides a systematic model for the establishment of ecosystem accounting in a co-ordinated way. In general, we agree that the SEEA Experimental Ecosystem Accounting requires further clarification on some technical issues before becoming an international standard. For example, when measuring the ecosystem degradation in monetary terms, the estimated values of using damage-based or cost-based perspectives may be quite different and more guidelines are required for choosing the two methods. In addition, given its multi-disciplinary nature, consensus among different parties (e.g. ecological scientists, biologists, statisticians) has to be reached, more researches have to be done and statistical systems have to be set up before the accounting system can be put up for practical implementation.
  The terminologies "ecosystem assets", "environmental assets" and "individual environmental assets" are used throughout the document, with discussions of their relationship with the SEEA Central Framework as well as SEEA Experimental Ecosystem Accounting in section 2.2. It would be useful to provide more explanations on the relationship and possible reconciliation of their coverage, preferably in the form of diagrams or tables and with practical examples. Table 3.1 clearly describes grouping and examples for the three levels of CICES. It would further facilitate users to better understand the overall flow if more guidelines about the coverage and definitions of each division and group, as well as a list of key data items and the proposed measurement units for each service could be provided. Section 3.4.4 has introduced the approaches to aggregation of ecosystem services, which include compilation of composite index and assignment of weight for individual items. It is proposed to elaborate in more details about the criteria and methods for determining the weighting. UNSD may also consider providing some examples about relevant indices being adopted by international organisations and other economies.
31/12/2012United States/Bureau of Economic Analysis1. We congratulate the Editor and the Board on the current draft of the volume and offer our sincere thanks for the time and effort that they have put in 2. Because the volume is inherently experimental, and because much of the material is so complicated that it cannot be adequately covered within a 150 page document, it would be prudent to cite the relevant academic literature throughout the text; particular attention should be paid to chapter 5. The citation of papers would be especially useful to readers who desire to educate themselves further. 3. There does not appear to be a single purpose to the volume. The title suggests that it provides aspects of how experimental ecosystem might be constructed. But such a posture is not maintained. In some places there are discussions of alternatives, while in others it is very prescriptive, particularly with regards to CICES and the ecosystem accounting units. 4. It is hardly emphasized that there is much ongoing debate about several features of ecosystem accounts, such as valuation, and that the link to the national accounts will not be straightforward or even possible. Moreover, any link to the national accounts must satisfy the crucial tenets that the computation of estimates be transparent and replicable. 5. The connection between service flows and beneficiaries is integral to the measurement of ecosystem service transactions. In certain places this is addressed, but the issue appears to be treated as another layer of information that can be overlaid on the Ecosystem accounting units. Because it is treated in an ancillary way, the connection to beneficiaries is often lost. See, e.g., the subsection beginning in 4.27 on degradation. Hypothetically, if ecosystems that generate no services experience a decrease in condition or extent, is it necessary to record degradation? From this section, the answer appears to be "yes", despite the fact that there is no reduction in expected ecosystem service benefits. 6. The sections and paragraphs relating to valuation of ecosystem services strongly suggest that the bulk of ecosystem service transactions occur without monetary valuation. For example, many of the cultural services may overlap with the SNA-defined economy, so that valuation would simply entail a re-classification of transactions recorded in the economy. Our point is that there are transactions already in the national accounts that may cover part or all of such ecosystem services. (This point is touched-on in 5.11, but the point is that it may extend beyond the provisioning services as discussed in 5.47-5.52 onwards, and that the discussion of valuation of cultural services in 5.57-5.59 is too narrow.) The overall preponderance of the text focuses on imputation, whereas we may find that re-classification accounts for much more of the ecosystem services than suggested. 7. Paragraph 6.4 contains examples of caveats that should be placed throughout the manual. Readers may not read the volume cover-to-cover, and hence these caveats should be placed next to the material to which they pertain. See accompanying document for more specific comments.
 EEA_USA.pdf;   
28/12/2012Germany/Destatis EEA_Germany.pdf;   
28/12/2012MauritiusThe structure of the document is well defined. However, a good description of ecosystem goods and services appears to be inadequate. These are important for health, social, cultural, and economic needs. General Comments Ecosystem accounting stems from the SEEA which articulates around the Environment and the Economy relationships. While a wide range of economic statistics is handily available with appropriate standard methodologies such as the SNA, such is not the case for Environmental statistics in many countries. The UNSD has therefore justifiably come up with the revision of the Framework for the Development of Environment Statistics (FDES). Therefore the Environment- can also better be measured/assessed with the FDES and then can be coupled with the economic statistics for compiling ecosystem accounts. The ecosystem approach will then be easily applied in compiling the accounts.
  Section 1.4 TO 1.6 The FDES could be a recommended framework for developing or initiating ecosystem accounts and meeting the accounting objectives as well as overcoming the measurement challenges. Sections 2.3 to 2.5 Some basic descriptions of GIS and Remote Sensing may add value to the methods for measurements in ecosystems. Sections 4.4 The IPCC guidelines for national GHG inventories are the recommended reference in carbon accounting. This could have been mentioned and listed. Some of the Figures/diagrams are bluured.
28/12/2012LatviaWe appreciate work done so far on ecosystem accounting. In general we agree that structure of document is good and is well written. As Central statistical bureau of Latvia are not involved in work with ecosystem accounting we cannot provide very specific comments on text.
27/12/2012KazakhstanThe structure and content is very coherent and the style is very appropriate. All in all we support and appreciate revision of SEEA. We are looking forward the third part of SEEA.
27/12/2012Australia EEA_Australia1.pdf;    EEA_Australia2.pdf;   
27/12/2012SwitzerlandWe consider the document an excellent foundation for organising information on ecosystems and on the services they provide. Especially Chapters 1?4 are conceptually sound. Chapter 5 provides important considerations on valuation for which, however we have some concerns (see Part II of this comment form). Paragraph 5.14 We support the existing paragraph: "Given the range of options that are available in the area of valuation it is recommended that where valuation is undertaken the purpose be clearly articulated together with a clear explanation of the underlying assumptions that have been made." Proposition: We propose however to add the following: "The meaningfulness of these values and the risk of under- or overestimation e.g. due to limits of scope or methodological restrictions should carefully be documented and systematically communicated." Rationale: Monetary valuation of ecosystems and their services remain a challenging field. Methodological choices within the accounts (e.g. the exclusion of non-use values or restrictions on the use of available welfare studies) may lead to values that do not capture the whole range of relevant benefits or values. The resulting values may, in some cases, be misleading, creating an illusion of accuracy while under- or overestimating the value of some ecosystems. Valuation studies outside the accounts may have the advantage to respond to well-defined policy questions. Specific studies would also be an opportunity to show a range of values based on a range of scenarios and assumptions.
  Paragraphs 1.52 - 1.55 Proposition: Please refer to the Framework for the Development of Environment Statistics (FDES) as an environmental building block for the SEEA ecosystem accounts (see http://unstats.un.org/unsd/environment/fdes/fdes_egm.htm). Paragraph 5.26 Proposition: Please explain more precisely the sentence "Since non-use value is based purely on the utility of an individual, it can be concluded that non-use values are solely comprised of consumer surplus and hence should be considered out of scope of national accounts based measures of value." Rationale: Don''t non-use values, in the same manner as use values, depend on supply and demand for the respective goods? We see no conceptual difference in identifying an exchange value for use or non-use values (while the practical challenges of estimating non-use values should not be denied). Paragraph 5.108 The paragraph on dealing with the sources of uncertainty is expressed quite openly . Proposition: We propose to add the following: "In any case it is necessary that valuations are accompanied by transparent information on (i) the scope of the valued ecosystems resp. services (ii) assumptions and uncertainties. Details: Paragraph 3.8: Proposition: We suggest to complement the existing paragraph, wich ends as follows: "This notion of ecosystem services is often referred to as "final ecosystem services" in that they are the final outputs that are generated and used from an ecosystem." by the sentence: "The concentration on final services helps to avoid double counting." Rationale: This would help to clarify the main message of the paragraph. Paragraph 4.13 Proposition: Please replace "benefit" by "feature": "A particular feature of using reference conditions is that ecosystems that are naturally more structurally diverse or species rich (e.g. tropical rainforests) are not necessarily assessed as having higher condition compared to ecosystems that are naturally less structurally diverse or species rich (e.g. Arctic tundra)." Rationale: If assessing very different ecosystems with the same weight is a benefit or problematic depends on the perspective applied. Not all ecosystems may be of equal importance from an ecological neither from an economical perspective. The examples of tropical rainforest and Arctic tundra may illustrate this well. Clarifications: The following paragraphs could be formulated more clearly: - In paragraph 2.82 it is not entirely clear to us, why "in situations where ''sustainable'' use is being made of the ecosystems, the estimation of total expected flows is not possible." - In paragraph 4.15 it is said: "While reference condition accounting leads to the recording of ecosystem condition scores between 0 and 100, these scores cannot be used to infer whether the condition of the ecosystem is good or bad." But will most readers not intuitively interpret a score of 100 as good and a score of 0 as bad? In Table 4.1 the connection between the accounting of cubic metres of water to the question of ecosystem condition is unclear to us.
27/12/2012SlovakiaStatistical Office of the Slovak Republic appreciates all efforts and hard work which were put into the development of the methodology for ecosystem accounting and in general agrees with the presented document. In our opinion, the document is well written, the structure of document is good and the balance of material seems to be adequate. The ecosystem accounting has not yet been introduced and developed within the Statistical Office of the SR so we are not able to provide specific qualified comments on this drafted methodology for ecosystem accounting.
27/12/2012Bosnia and HerzegovinaAgency for Statistics of Bosnia and Herzegovina welcomes adoption of international standards System of Environmental-Economic Accounting (Central Framework). SEEA is a framework for an interdisciplinary approach, which describes the interaction between the economy and the environment, and provides a comprehensive and user-friendly view for countries in this matter, and international comparisons. There is no experience in Bosnia and Herzegovina in this matter. It was only conducted a pilot study- Environmental expenditure on a limited number of reporting units, with the goal of understandability questionnaire. Further work is required to develop these statistics. Agency for Statistics of Bosnia and Herzegovina has taken action on the translation of Chapter 1: Introduction to the SEEA Central Framework, for purpose of popularization of this document and informing the public with this matter in Bosnia and Herzegovina. Translated Chapter 1 will be posted on the website of the Agency for Statistics of Bosnia and Herzegovina (www.bhas.ba)
27/12/2012South Africa, South African National Biodiversity Institute SANBI has only recently been exposed to the work being done on developing SEEA Experimental Ecosystem Accounting. Due to this fact, as well as looming annual vacations and the deadlines that come with this, we are unfortunately unable to make comments on this substantial draft document given the short amount of time. However, SANBI sees this work as very important both nationally and internationally, and would like to take this opportunity to ask to be involved in further development of SEEA Experimental Ecosystem Accounting. As a national public entity, SANBI has done a great deal of work on mapping and classification of ecosystems nationally in terrestrial, freshwater and marine environments, as well as assessing the condition of these ecosystems (some of this work is summarized in our recently published National Biodiversity Assessment synthesis report and technical reports, available at http://bgis.sanbi.org/). We would greatly appreciate an extension of the commenting deadline to the end of Jan 2013. However, if this is not possible, we would still like to request to be involved in this evolving work going forward. SANBI also intends on meeting with the South African NSO in the new year to discuss possible collaboration on developing ecosystem accounts.
27/12/2012PolandWe are of the opinion that the work done so far is good, although further analyses and definition establishing are required to successfully complete this work. The style, tone and readability is not a concern, as it is truly appropriate from our point of view.
  Following previous general comment we can see that e.g. some rethinking would be welcome in the subchapter 6.4.2 Wealth accounts where some unclear statements are adopted. Mineral and energy resources (item 6.51) and energy from renewable sources (item 6.53) can be considered as land resources and this is not clearly explained. Water (item 6.54) and water in marine areas (item 6.55) are treated very differently, although both can be subject to losses, because of e.g. pollution, particularly in case of small and/or inland seas, such as Baltic Sea.
27/12/2012PalestineThe chapter provides an adequate overview
27/12/2012NorwayThe draft text has brought together knowledge of statisticians and environmental experts and for the first time there is a comprehensive attempt at giving a consistent presentation for ecosystem accounts. That statisticians have been involved in trying to consolidate this work has hopefully helped to translate often unclear needs into more measurable frameworks. But we wish to point out that, in our view, ecosystem accounting is still only at an experimental stage of development and much more work in trying to implement and populate some of the proposed tables is needed, as in fact is suggested by the editorial group in their call for "experimental" efforts by the countries giving priority to this work. What has been described in the report is at a very theoretical or conceptual level and it may be difficult to envision how many of the ideas being presented can be developed into meaningful accounts for practical purposes. With a focus on the text directly, the consultation draft seems rather fragmented and it is difficult to understand exactly how the different chapters relate to each other. One reason may be that much of the important conceptual discussion has been placed in the many annexes referring to many different chapters at the end of the report which makes it difficult to get a comprehensive impression of the relationship between the core concepts. We recommend that the most important parts of these annexes are moved back into the main text. This appears to be a work in process – a progress report – rather than any type of manual that could be considered as part of a "SEEA" family of manuals. There seems to be a number of important "parts" of a system being described but it is still unclear exactly how the different parts fit together into accounts. There is a need for substance and methodology which may be the result of an "experimental" practical application of this framework carried out in the countries giving this priority. The text does try to establish a common set of terminology which can be used for further work. Until now there has been a flourishing of divergent terminology which has often caused confusion. Consolidation of the terminology is an important first step.
   EEA_Norway.pdf;   
27/12/2012HungaryHowever we appreciate the progress on ecosystem accounting the Hungarian Statistical Office do not wish to comment the document in this preliminary phase. On the one hand the topic is far beyond the scope of statistical practice and on the other hand further clarifications and amendments should be made for the development of the document.
27/12/2012German Federal Agency for Nature Conservation The document clarifies a lot of the questions that were raised in the preceding discussions between statisticians, environmental economists and ecologists of different professions on the challenges and ways how to integrate biodiversity, ecosystems and ecosystem services into environmental economic accounting. These questions regarded especially but not exclusively. - the role of the production boundary in the definition of services, - the interrelationship between SNA, SEEA Part I and SEEA Part II, experimental ecosystem accounting, - a system of units for ecosystem services accounting, - data requirements for the evaluation of ecosystem services consistent with the economic concept of value, - differences in concepts and measures of value in SNA compared with welfare/environmental economics. By giving basic answers to these questions and showing ways how to systematically solve the different problems of ecosystem accounting aligned with common accounting principles and methods this document provides an excellent and urgently required common basis for the (still) heterogenous "ecosystem accounting community" to foster additional internationally and interdisciplinary more coherent efforts on the development of, first, experimental ecosystem accounts and – as the last step – for practical, scientifically sound and commonly accepted (standard)solutions to integrate ecosystem services and natural capital into SEEA and SNA. For detailed comments see Part II (The Federal Statistics Office of Germany will receive a copy of this comment. Despite the exchange between BfN and German Statistics Office on ecosystem accounting it was due to time shortages unfortunately not possible to integrate the comments of both agencies and send a joint version)
   EEA_German_BfN.pdf;   
27/12/2012AzerbaijanIn my opinion the structure of the document, the balance of material and the coverage of the draft are satisfactory.
  In my opinion the Part II of the document also is satisfactory and does not require any corrections.
27/12/2012AustriaWe regret having to state that we reject the approach laid down in the Exposure Draft for SEEA –Experimental Ecosystem Accounts. There are two main reasons: • As already stated in our comment on the System of Environmental-Economic Accounts (asset accounts) figures on stocks and also on environmental services whether in physical or monetary terms cannot tell anything about the quality of ecosystems (state and changes in state of ecosystems). We do not see how figures on stocks and flows of ecosystem services could show the changing condition and health of ecosystems and their capacity to continue to deliver benefits to humanity. In our view there is a contradiction because an ecosystem''s capacity to deliver ecosystem services depends on its state. How to measure the "condition" of an ecosystem? The meaning of several paragraphs is unclear, especially the way ecosystems and their services as well as their relation is understood in the document seems strange (see also remarks on 1.17, 1.35, 1.61, 2.4). • We do have only in a few cases data to fill in the tables. It would afford an enormous amount of resources (monetary and non-monetary) to gather the necessary data. We doubt that it would be in balance with the advantage. But apart from that we think that in many cases it is factual impossible to generate figures; see also remarks on Table 2.1, 2.4, 3.2, 4.6. We are even missing clear definitions, e.g. do you mean by ecosystem services only those which are used? Is your perception of an ecosystem service the resulting product, e.g. crops, or is it the function of the ecosystem to produce crops? We are generally very sceptical against monetary valuation of ecosystem services.
  1.17 "Ecosystems – the dynamic complexes of biotic communities interacting with their non-living environment" Ecosystems are living systems and can therefore not be characterised only by flows from or in the non-living environment. 1.34 "Biodiversity affects ecosystem functioning, …" The expression "biodiversity" is used here in a way which cannot be understood. 1.35 "… the capacity of an ecosystem to provide ecosystem services depends on … the condition of the ecosystem." What do you mean by the condition of an ecosystem, its state? We think that also climate, radiation, light and changes of light may influence the possibility to provide ecosystem services. 1.61 We don''t think that biodiversity is an environmental feature which can be accounted in the SEEA Experimental Ecosystem Accounts. 2.4 "An important … characteristic of ecosystems … is its biodiversity." We think that the word Biodiversity is used here wrongly. Biodiversity is an expression which tries to summarise the diversity of our living environment. Ecosystems are elements of nature. The diversity of ecosystems as well as the diversity of the living elements of ecosystems and their relations are among others part of what is described usually with the expression "biodiversity". In the following chapters "biodiversity" is used as an aspect of condition, which is in our view totally unclear. Table 2.1 and 3.2: We think that for some ecosystem functions these tables cannot be filled in. The generation and the use of the ecosystem service "flow regulation" cannot be assigned to enterprises or the government, e.g. Table 2.4 and 4.6: In many cases there will be several causes for the change of ecosystem service having an additive, synergistic or concurring impact. Thus within the groups "changes in extent, condition, utilisation" there would be at least relative estimates be possible.
 

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