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UNITED NATIONS SC UNEP/POPS/POPRC.8/INF/21 Distr.: General 11 September 2012 Stockholm Convention on Persistent Organic Pollutants English only Persistent Organic Pollutants Review Committee Eighth meeting Geneva, 15–19 October 2012 Item 5 (i) of the provisional agenda* Technical work: intersessional work on climate change and persistent organic pollutants Comments and responses relating to the draft guidance on how to assess the possible impact of climate change on the work of the Persistent Organic Pollutants Review Committee Note by the Secretariat The annex to the present note contains a table listing comments and responses relating to the draft guidance on how to assess the possible impact of climate change on the work of the Persistent Organic Pollutants Review Committee, set out in document UNEP/POPS/POPRC.8/INF/20. It is presented as submitted by the intersessional working group, without formal editing. * K1282619 UNEP/POPS/POPRC.8/1. 180912 UNEP/POPS/POPRC.8/INF/21 Annex Comments and responses relating to the draft guidance on how to assess the possible impact of climate change on the work of the Persistent Organic Pollutants Review Committee Minor grammatical or spelling changes have been made without acknowledgment. Only substantial comments are listed. Source of Comment Bulgaria 2 Page Chapter General Bulgaria General Bulgaria General Bulgaria General Bulgaria General Bulgaria General Bulgaria Annex D Comments Please add an executive summary at the beginning and recommendations at the end. Recommends a “Table of Contents”, “List of Tables” and “List of Figures” to be added at the beginning of the document Enhance readability by starting each chapter on a new page. Add: Information on climate change (as a short introduction) would be also useful, shall improve generally the guidance. Such an introduction is now missing and thus a definition of “climate change” is lacking. The division in changes in temperature, salinity, and irradiation is very useful, but it would be appreciated if this would be applied throughout the text where often “climate change” is used while the relevant factor is change in temperature and so on. The draft guidance does not make a very clear difference between facts, data and figures from past and present as provided by scientific studies and predictions based on events that are expected to happen in the future. Throughout the text a lot of “can be”, “may be” and “will be” can be found. We consider that “may be” is better to used throughout the text, due to the fact that no figures of the uncertainties in the predictions are provided in the text. Change: Documentation of interactions between a nominated substance and climate change shall be collected by the nominating Party Delete: shall Add: may Response Accepted Noted. This would be practical, but because of the need to keep documents short it was not done. Noted. Partly accepted. The scope and mandate of the task set out by POPRC7 was to base the guidance on UNEP/AMAP 2011, and a short introduction on interactions and impact between CC and POPs already exists in the document. To summarize the findings by IPCC would be out of scope of this guidance. However a short introduction on climate change has been added, but only on the impacts relevant according to the report by UNEP/AMAP 2011. Noted. Partly accepted. The terms «may be», «will be», «can be» are often the language of the original sources and it is difficult to change it without changing the tone. However the text has been modified on the basis of other comments and the essence of this comment. The words "can be”, “may be” and “will be” have to a large extent been replaced with "have been/ was observed" and "is predicted to/projected to" to more clearly distinguish between observed and predicted/projected effects and to make the level of certainty in the cited data/ results more clear. Partly accepted. Should is used in the text. UNEP/POPS/POPRC.8/INF/21 Source of Comment Canada Page Chapter Executive summary Canada 5.1 Canada 5.1 Canada 5.1 Canada 5.1 Canada 5.1 Canada 5.1 Canada 5.1 Canada 7 Canada 7 Canada 7 Canada 7 Canada 7 Canada 7 Canada 7 Comments This executive summary could be use more work to improve clarity, flow and grammar. It would appear that much of the text below has been cut and pasted from other sections section 5.1 and Chapter 7 in particular. The POPRC should be mentioned early in this paragraph Several editorial comments provided including use of abbreviation “CC” for “climate change”. Insert “transport in air” in the first sentence of the first paragraph. Insert “presenting information on” instead of “discussing” in the third paragraph. Insert “of a candidate POP. These considerations also apply” instead of “as well as” in the third paragraph. Insert “CC-related are especially important” instead of “the climate change will be of especially importance” in the fourth paragraph. Insert “as we move” instead of “in the light of movement” in the fourth paragraph. “Sustainable development” in the fourth paragraph is a bit vague. A few more words of explanation are required here to explain what the sustainable development is referring to. Last paragraph, “in relation to the criteria in the annexes” requires more explanation. Which criteria and in which annexes? Overall, this section could be revised with clearer language and perhaps a clearer format in which conclusions and recommendations are clearly identified. “This exercise” in the first paragraph is unclear. What exercise? Also suggest that this section begin with a more definite statement. Insert “are relevant to and should be considered when assessing” instead of “can be evaluated in light of” in the first paragraph “Criteria” in the first paragraph needs more specificity – what criteria? “Clearer taken into account” in the second paragraph: Rephrasing required. “Recommended to add” in the second paragraph: Is this suggesting that the Annexes to the Convention need to be formally revised? If so, this should be clearer. Perhaps also include a statement about how this revision can be achieved. Insert “This is in addition to risks associated with” instead of “in addition to the” in the third paragraph. Response Received late. Comments to be considered. Not accepted. Accepted. Accepted. Text rewritten. The whole text deleted. The whole text deleted. The whole text deleted. Accepted. Section revised and divided into to subchapters. Accepted. Words added and section rewritten. Accepted. Accepted. Text revised. Accepted. Text revised. Accepted. Text revised. Text changed, to make clear that climate change and multiple hazardous substances is an example of environmental stressors. 3 UNEP/POPS/POPRC.8/INF/21 Source of Comment Canada Canada Chapter 7 7 Canada 7 Canada 7 Canada 7 Canada Executive summary Canada Colombia Executive summary General Colombia 5 Colombia 4 Page Comments Response Insert “to multiple” instead of “of a cocktail of” in the third paragraph. Insert “CC-related effects” instead of “observed climate change effects” in the third paragraph. Third paragraph: Some wordsmithing is required here Fourth paragraph: Be clearer here. This reads as more of a summary than a conclusion. This section could be more concise and would benefit from some wordsmithing. Fifth paragraph: This paragraph needs to be reworked. Suggest that the recommendation to assist developing regions to address the CC effects issue simply be tagged onto one of the earlier recommendations. The wording of the first sentence should be adjusted. Each paragraph should begin with a new conclusion. This paragraph begins with an action item. Not clear what process is referred to. Unclear what is the “scarce information”. This executive summary could be use more work to improve clarity, flow and grammar. It would appear that much of the text below has been cut and pasted from other sections section 5.1 and Chapter 7 in particular. Accepted. First para: The POPRC should be mentioned early in this paragraph. The document contains valuable information that will serve to guide the work of the POPRC, concerning the effects of climate change and the behavior of POPs. In section 5.2.1. Persistence (a) The effects of climate change on persistence, states that "while Increased temperatures may increase the microbial activity, Increased thermal stress may hamper the activity (UNEP / AMAP 2011)", I suggest you include the following: appearance which can increase the biodegradation of POPs. Studies show that the effects of climate change influence on POPs characteristics such as persistence, bioaccumulation, potential for longdistance transport and adverse effects, which as noted in the text are evaluated for a variety of controlled conditions, but in many cases not consider the real environmental conditions. Considering that the document seeks to guide the work of the POPRC to establish the effects of climate change in relation to the behavior of persistent organic pollutants, according to the criteria set out in Annexes D, E and F of the Stockholm Convention, recommend Accepted. Text revised. Accepted Accepted. Section revised. Accepted. Section revised. Accepted. Section revised. Accepted. Text revised. Noted. Not accepted. The uncertainties will be different for every substance, impact, scientific test/observation and region, and even more complex than the estimation of climate change impacts done by IPCC. At this stage we do not know which substance will be nominated. POPRC should be able take into account any uncertainties given in the specific data presented on CC impacts on a specific substance, derived from laboratory studies or field experiments/observations the same way it does now with other data on properties etc. UNEP/POPS/POPRC.8/INF/21 Source of Comment Page Chapter Ecuador General Ecuador General Ecuador General Ecuador General Georgia General The Netherlands Annex D Comments Response defining the criteria to be considered for laboratory studies and field such as: the range of increasing temperature, increase or decrease in rainfall, increased ultraviolet radiation, changes in salinity, lower pH, etc. considering the criteria adopted climate change experts, the above to have a unified approach by the POPRC. The guidance underlines that any predicted or observed effects should be considered on a case-by-case basis (i.e. chemical per chemical) using what is available of data for the specific substance. The uncertainties given in the scientific data is then also included in the evaluation, in a weight-ofevidence approach, as has currently been the practice of POPRC in the past. Climate change has the potential to alter the hazardous properties of environmental contaminants, so it should include information from other areas of the planet. Only thing recorded are more frequent extreme weather. Arctic Monitoring and Assessment Programme (AMAP) data is very important. Add: The results obtained from the analysis of data from 20 years of air monitoring in the Arctic, show that if conditions remain or become warmer it would release a larger amount of persistent organic pollutants into the atmosphere. •You are kindly asked to include information about the other zones of the planet where extreme climate changes, such as flooding and heat waves, are registered more frequently, and where interesting data/facts about this topic have been reported. • Additionally it is suggested to strengthen the synergies between the political agendas of climate change and POPs related to identifying areas of uncertainty, gaps of information, knowledge and data at the global level and in particular of the countries in the process of development in order to have a more complete and detailed report. Due to all the alterations the environment globally is going through because of climate change the monitoring plans must be extended to increase the generation of information in all the signatory countries of the convention to the moment when a harmonized and general strategy is established. We consider (from our point of view i.e. Climate Division) no proper attention is paid to the interaction between climate change and POPs in mountainous areas in the Guidance. Climate change does not change the characteristics of the criteria in annex D, but may change their reasons for concern. That should be clear throughout the text of the document This is clarified in the text. Agreed. A table on regional differences is added, with information from all regions mentioned in the IPCC report. Agreed in principle, but a reference is needed to be able to include this sentence. Accepted. Partly accepted. See text added to the recommendations in chapter 7 and in the Executive Summary. Agreed, but references are needed to be able to include more information on mountain areas. The need to generate more information has been noted in the recommendations. Agreed. Text modified to make this clearer in the text. See also added/modified text in objective and chapter 5. 5 UNEP/POPS/POPRC.8/INF/21 Source of Comment The Netherlands Page 25 The Netherlands Table 7 Comments Authors states that climate change does not change the inherent properties of the substance, but they seem to have forgotten that in other parts of the guidance document. Please correct such flaws Annex D The Netherlands The Netherlands Chapter As nomination of substance should be purely based on the annex D criteria, data on the effects of climate change can only support nomination in terms of reasons of concern. In climate change related data the Netherlands would express a strong preference to use specific data on these substances rather than generic ones. General The Netherlands would be in favor of a recommendation whether the subject “climate change” should be addressed either in the nomination dossier or the risk profile or the risk management evaluation. Annex D, E and F Table 7 of present draft shows a complete overlap of subjects in annex D and E, and only one item in annex F The Netherlands General The Netherlands 4, 5 and 6 The Netherlands General The document would be greatly improved by adding an executive summary and a recommendations section Start on a new page to increase the readability and text should have consistency Add: general information on climate change predictions Response Agreed. Corrected text/modifications of the text to make this clearer in chapter 4 and 5. In addition have new text been added to make this still clearer in the document. See added text in objective and chapter 5. Agreed. But the document already states that CC data in the screening stage only should be used in terms of reasons of concern. Use of generic data is not recommended in the text, only data on analogous substances where scientifically supportable. New text added to make this still clearer in the document. See added text in objective and chapter 5 and 6. The mandate from POPRC 7 was to consider relevant data on CC in all stages. The scope and mandate of the task set out by POPRC7, was to base the guidance on UNEP/AMAP 2011. From the conclusions and recommendations in the report all stages will be relevant. However, some may have more weight than others. This is now clearer spelled out in the text. The table is not fully developed in 2nd draft, as also noted in the text. In annex E the criteria in annex D are used. But to do the evaluation of environmental fate and the hazard assessment more data are needed and other aspects would need to be included in the evaluation (see risk profile outline). The table, however, has been deleted for other reasons. Accepted. Noted. Text revised. Partly accepted. The scope and mandate of the task set out by POPRC7, was to base the guidance on UNEP/AMAP 2011, and a short introduction on interactions and impact between CC and POPs already exists in the document. To summarize the findings by IPCC would be out of scope of this guidance. However a short introduction on climate change is added, but only on the impacts relevant according to the report by UNEP/AMAP 2011. 6 UNEP/POPS/POPRC.8/INF/21 Source of Comment The Netherlands The Netherlands The Netherlands Page Chapter Comments General Should be a clear distinction between facts and data from scientific studies and predictions General Relations with the obligations if the convention should be clear Guidance would be greatly enhanced when a short introduction on climate change is added together with relevant references. Such an introduction is now lacking and this „climate change“ is not defined General The Netherlands General The Netherlands General The Netherlands General It would be appreciated if there was division throughout the text where often “climate change” is used while the underlying factor is change in temperature The guidance does not make a very clear distinction between facts, data and figures from past and present as provided by scientific work and predictions based on events that are expected to happen Abundance of “can be”, “maybe” and “will be” can be found. No figures of the uncertainties in these predictions are provided in the text. Response Accepted. The words "can be”, “may be” and “will be” have to a large extent been replaced with "have been/ was observed" and "is predicted to/projected to" to more clearly distinguish between observed and predicted/projected effects and to make the level of certainty in the cited data/ results more clear. However it should be noted that much of the statements made in the text and the use of the words "can be”, “may be” and “will be” are derived directly from the UNEP/ AMAP 2011 report. Agreed. See changes in chapter 5. Partly accepted. The scope and mandate of the task set out by POPRC7, was to base the guidance on UNEP/AMAP 2011, and a short introduction on interactions and impact between CC and POPs already exists in the document. To summarize the findings by IPCC would be out of scope of this guidance. However a short introduction on climate change is added, but only on the impacts relevant according to the report by UNEP/AMAP 2011. Not accepted. Have not found places where this has been relevant. Accepted. The words "can be”, “may be” and “will be” have to a large extent been replaced with "have been/ was observed" and "is predicted to/projected to" to more clearly distinguish between observed and predicted/projected effects and to make the level of certainty in the cited data/ results more clear. However it should be noted that much of the statements made in the text and the use of the words "can be”, “may be” and “will be” are derived directly from the UNEP/ AMAP 2011 report. Not accepted. The aim of this text is to highlight climate change effects on POPs, both predicted and observed, that POPRC should be aware of and consider when evaluating new substances for listing. As decided by POPRC7 the text is based on the UNEP/ AMAP 2011 report, which makes predictions on climate change effects on POPs. The UNEP/ AMAP 2011 report does not estimate the uncertainties, hence neither does this guidance. Given the novelty of the topic. the guidance, as well as the UNEP/ AMAP report, contains quite a substantial 7 UNEP/POPS/POPRC.8/INF/21 Source of Comment Page Chapter Comments Response number of "field data" or "field observations" i.e. scientific reports on climate change effects on POPs that are/ have been observed in real life in the wild and not only in the lab. In the UNEP/ AMAP 2011 report and the guidance these "field" data are used along with data from controlled lab studies and model estimates to make more generalized predictions. Hence although the UNEP/AMAP report makes predictions these predictions are rooted in actual observations. The uncertainties will be different for every substance, impact, scientific test/observation and region, and even more complex than the estimation of climate change impacts done by IPCC. At this stage we do not know which substance will be nominated. POPRC should be able take into account any uncertainties given in the specific data presented on CC impacts on a specific substance, derived from laboratory studies or field experiments/observations. Since the evaluation of uncertainties will not be different from evaluation of uncertainties in other data presented to POPRC in the past evaluations. The guidance underlines that any predicted or observed effects should be considered on a case-by-case basis (i.e. chemical per chemical) using what is available of data for the specific substance. The uncertainties given in the scientific data is then also included in the evaluation, in a weight-ofevidence approach, as has currently been the practice of POPRC in the past. The Netherlands 8 Annex D The Netherlands 25 The Netherlands 8 Chapters 4 and 5 Change: Documentation of interactions between a nominated substance and climate change shall be collected by the nominating Party Delete: Shall Add: may Clear link needed between statements and conclusions in chapter 5 and those in chapter 4. Chapter 5 states “Field studies and monitoring data indicating increase in persistence with climate change.” However the text in chapter 4 on persistence and Table 2 suggest that the trend is to a shorter half life time rather than to a higher persistence. Lack scientific backing, reference needed: “POPs with endocrine disrupting properties This is made clearer in the text. Accepted. Not accepted. This is related to statement of reasons of concern, and is not a general evaluation. See new text. Changes have been made to the text. References were added to the text to provide documentation for the statement that POPs can have endocrine disrupting properties. UNEP/POPS/POPRC.8/INF/21 Source of Comment The Netherlands Page Chapter Comments Change: “POPs with endocrine disrupting properties is adding to this concern, since the endocrine systems is important for Arctic mammals to respond adequately to environmental stressors, cognitive learning, reproduction and sexual behavior (Letcher et al. 2010; Jenssen 2006).” Review: Citation summary Jenssen (2006): “Even though behavioral and morphological effects of persistent organic pollutants are consistent with endocrine disruption, no direct evidence exists for such relationships.” Review: “However, the usage are still of importance as shown by the study contributing to the levels found in the Adélie penguins living in the Antarctica due to its long-range transport, and is adding to the releases from the melting glaciers” Edit: statement should be backed-up with analysis of the origin of the DDT found in the penguins i.e. not clear on the amount of concentration of DDT in the penguins originates from the present usage. 8 The Netherlands 11 The Netherlands 11 Review: The survey revealed remarkably higher levels of dichlorodiphenyl trichloroethane (DDTs) in the flooded arable soil than in reference soil samples. Edit: No information is provided on the reference soil samples, so it is not if the soils are comparable in composition. The Netherlands 18 Sudan 4 3 Sudan Sudan 5 5 4.1 4.1(a) Table 2: There is no reference in the text to the temperature dependency of homeotherms. Not clear on which data this statement is based on. Para 1: Where are the other 3 sections, are they the above 3 parts, if so change to sections or parts in the two para. Check figures Para 1: Climate change on the different global regions (Check with IPCC doc). Impacts always depend on rise of temperature no matter in which region. Level of impact varies from region to Response Changes have been made to the text in chapter 4.1 (c) to address this concern and to clarify that the statement made by Jenssen et al. 2006, that relates to the difficulty of proving cause and effect relationships in wild organisms. Accepted. Several changes in the text also made in light of other types of comments, to make the findings from this study clearer to the reader. The findings Geisz et al. (2008) suggest that climate change induced ice melting may be a source to DDT exposure in Adélie penguins living in Antarctica. The authors of the study did not perform an analysis to identify the origin of the DDT in the penguin samples themselves, but leans on other data showing an increase in DDT releases due to ice melting in the area. To mirror the text of the cited paper and make it clearer what "reference" in this context means the "word reference soil samples" has been replaced with "reference (non-flooded soil)". However, that the survey revealed remarkably higher levels of dichlorodiphenyl trichloroethane (DDTs) in the flooded arable soil than in "reference" soil samples is the authors' own statement and should not be changed. With regard to the comparability of the soil samples the guidance do not go into such details. The details about their comparability may be found in the materials and methods section of the paper which is a published and peer-reviewed study (i.e. its contents and conclusion including its the comparability of the soil samples have been evaluated by external reviewers and have been found sufficiently good for publication). Accepted. Text changed to poikilothermic organisms. Accepted. Text is changed. Accepted. Text is changed. Accepted. Text is changed. 9 UNEP/POPS/POPRC.8/INF/21 Source of Comment 10 Page Chapter Sudan 6 4.1(a) Sudan 6 4.1(a) Sudan 7 4.1(b) Sudan Sudan 7 8 4.1(c) 4.1(c) Sudan 8 4.1(c) Sudan 9 4.1(c) Sudan 14 4.2(d) Tanzania General Tanzania General United States 4 2 United States 4 3 United States 5 4 Comments another depending on the region. So the variation of impacts that depend on the region not the impact itself. Para 4: A warming climate may also alter the migration patterns of contaminated species (e.g., fish and seabirds), and may cause future transport of POPs to previously uncontaminated regions – sentence not clear/how? Para5: What is the impact on POPs here? Reference? Para 3/4 and 5: How? Reference needed. Needs to be more clear Para 2: how again? Para 4: No relevance to climate change regarding to Para 5: Same as above no clear link Para 10: Do you mean that when there is a decrease in agriculture and livestock due to C. C you increase the use of pesticides, link is not clear enough with C.C. Para 2: True but no clear relation with the POPs here. (a) Typographical and grammar which we are confident the Secretariat will have noticed; (b) To ensure that the objective of the guidance document i.e. to incorporate the complex climate change interaction with POPs are identified deliberate intervention by the Secretariat will be required to enable developing countries to effectively participate in the process. This is particularly important as climate change effects will be different in magnitude and variability in different regions. And as such if developing countries are not assisted, some effects may go unnoticed for a fairly long time. Change: climate change on the substance under evaluation, Add: climate change even if there is not specific information on the chemical under evaluation, consideration can be given to data on analogous substances where scientifically supportable Para 1: it is unclear if the three parts being referred to are distinct from the Sections 4-7 below or if Sections 4-7 make up the three parts. Also, if the three parts consist of Section 4-7, it is confusing that there are four Sections representing three parts. Citation needed: Climate change will alter salinity, ocean acidification, eutrophication, water oxygen levels, and the nutritional status of species and their adaptability Citation needed: Toxicity and toxicokinetics of POPs could be altered as a direct result of changes in temperature Response Text added to make this more clear. Text added to make this more clear. Text added to make this more clear, and references added. Text added to make this more clear. Text changed to make the link to CC in the para more clear. Text changed to make the link to CC in the para more clear. Text added to make this more clear. Text added to make this more clear. Noted. Partly accepted. See text added to the recommendations in chapter 7 and in the Executive summary. Accepted. Accepted. Text is changed. Accepted. UNEP/POPS/POPRC.8/INF/21 Source of Comment United States United States Page Chapter Comments Response Unclear what kind of regional variability is referred to here. There is variability between regions in how large the increase in temperatures is observed to have been and is projected to be. Have not found any statements that some regions may cool in the observations and projections by IPSS. See the added text from IPCC 2007 b, c. See the added text from IPCC 2007 b, c. 6 4(a) Para 2: This is factually incorrect. Some regions may cool in a warmer. Could clarify the statement to read “Each of these climate zones are very likely to experience varying degrees of warming as global temperatures increase, though strong regional variability will exist”. 6 4(a) United States 6 4(a) United States 6 4(b) United States United States 7 4(b) 7 4(b) United States 7 4(b) United States 8 4(c) United States United States United States 9 4(c) Para 3: These statements are all too definitive and do not reflect the current state of climate science in the sense that a large degree of regional variability is likely. These statements either need to have caveated language citing regional variability OR perhaps better would be to take statements directly from IPCC’s AR4 WG1 report (2007). Para 5: This has not been observed yet, but it is projected to occur if the stratosphere continues to cool. Para 2: Increased heat and sunlight do not cause changes in salinity as much as freshwater inputs (and other factors) do. See first para on next page which is much more accurately stated. Para 4: Have wind speeds increase over all of the oceans? Para 6: Will the trend *increase* or *continue*? These are two very different consequences. Check the Schiedek reference. Para 6: Perhaps list some areas that will be affected; these are NOT global impacts, so stressing the regional difference is important for local decision-makers. Para 8: What is meant by this “species composition”, physical composition (physiology) of species? Please define this acronym – OHC 9 4(c) Para 9: Ever what? Due? Text revised. 9 4(c) Agreed. Text added. United States 10 4.2 (a) Para 10: The link between pathogens contaminating food as a result of extreme weather is not intuitive and deserves more elaboration. Also, this will not be observed similarly across the globe. The scientific community’s understanding of how climate change will impact extreme events is in its infancy, so please take great care in drawing links between extreme weather and climate change. Para 2: First time the term “legacy POPs” has been used and is worthy of being defined. United States 10 4.2(a) Para 3: Release of What? DDT? Not clear. Unclear what kind of regional variability is referred to here. There is variability between regions in how large the increase in temperatures is observed to have been and is projected to be. Accepted. Text changed. Not agreed. This sentence is referring to open ocean waters, where fresh water inputs have less influence on the salinity, and is correct according to the references used. See added text Text added to make this more clear. Accepted. Text changed. Accepted. Text added. Text reworded. Text revised. “Legacy POPs” has been removed and the specific substances added instead. “Legacy POPs” has also been removed in other places. Accepted. Text added. 11 UNEP/POPS/POPRC.8/INF/21 Source of Comment United States 12 Page Chapter 11 4.2(a) United States 11 4.2(a) United States 12 4.2(a) United States 12 4.2(a) United States 12 4.2(a) United States United States 13 4.2(b) 13 4.2(b) United States 13 4.2(c) United States 13 4.2(c) United States 14 4..2(d) United States 14 4.2(e) United States 15 4.3(a) United States 15 4.3(a) Comments Para 5: Is this accurate? Seems odd that one site would continue to observe this “pulse” years after the event itself since wind would transport these pollutants away, typically…unless there is a continuous source of revolatilization? Para 6: This is an unsubstantiated statement, attributing any single extreme event to climate change is virtually impossible and subject to great uncertainty, so it is best to avoid such statement altogether. Para 7: As stated above, this is also an unsubstantiated statement. We suggest that this sentence is deleted. Para 8: Not a globally true statement. Characterize with appropriate regionally-specific language Insert citations Para 8: Do we really have reliable records of these events – and the consequent extreme events associated with them – to make such bold statements – prior to 1900? Can this be gleaned from paleo data? Para 3: Why are subtropical latitudes called out explicitly? Para 4: Was this a region-specific study or are the findings relevant to ALL soils ALL over the word? Para 1: Again, less definitive statements would be more scientifically accurate; i.e. “is projected to”, etc. Para 2: Might be worth pointing out somewhere that – as noted earlier – both more rain/more drought – like conditions can both cause an increase in POP mobilization. Para 2: How does an increased environmental exposure (to POPs) cause an increase in the levels of food and water? Not clear Table.1: temperature – again, for all of these taper down the definitive nature of the statements to more accurately reflect the state of the science, “increase temps are projected to cause an increase in the water….” This comment applies to the entire table. Para 1: How does this effect compare to the INCREASE revolatilization of POPs due to increased rainfall and drought in other areas?? Para 2: Particles are not necessarily lipids? In fact most airborne particulate matter is not lipid-based, but largely inorganic (black carbon, sulfate, nitrate, etc.). In short, it is not clear what the relevance of lipid affinity is here. Response Accepted. Text added. Agreed. Text from IPCC reports added on this matter. Agreed. Text from IPCC reports added on this matter. Not accepted. Text added from IPCC report. Conclusion from IPCC 2007 report and Li have used records 1,100 years back in time on drought reconstruction based on tree ring records. Citation added. See explanation under 4.1.b Text and more references are added. Accepted. Not agreed. It is mentioned elsewhere in the document, but does not imply to be mentioned in the concept explained here. See added text. Agreed. Text added. Accepted. Text revised. Increase in rainfall and drought may give a remobilization of POPs to air and water, due to soil erosion and evaporation. This is not connected to persistence dealt with in this section. But perhaps the question has been misunderstood. Text changed to be more precise. UNEP/POPS/POPRC.8/INF/21 Source of Comment United States United States United States Page Chapter 15 4.3(b) 17 4.4 18 4.4 United States United States 18 4.5( a) 19 4.5(b) United States 19 4.5(b) United States 20 4.5(b) United States 20 4.5(b) United States 21 4.5(c) United States 22 4.6(b) United States United States 23 4.6(b) 24 4.6(C) Comments Response Para 1: How is this defined? More favorable for what? Para 1: Specific dependent (What is meant by this???) Para 7: Change will cause (Again, less definitive statements would be more scientifically accurate “climate change is projected to….” Etc. Para 1: What are environmental “compartments”? Para 1: We suggest citing the Hemispheric Transport of Air Pollutants project (HTAP) that had a specific section on long-range transport of POPs: http://www.htap.org/activities/2010_Fi nal_Report/HTAP%202010%20Part% 20C%20110408.pdf Para 4: lipid affinity (Again, not sure where lipid affinity comes into play from an atmospheric chemistry standpoint?) Para 6: Some photolytic reactions DO have a strong temp dependence Cite the more recent IPCC report from 2007 (Macdonald, 2005) - There is a heavy reliance on this single study throughout this section. It might be worth looking for more recent/diverse investigations into this area. Read and cite the HTAP report, which is a comprehensive assessment of the topic. Also, check of the ARCTAS field campaign: http://www.espo.nasa.gov/arctas/ Para 7: What is the “polar dome”? the dynamical polar vortex of atmospheric circulation? Text revised. Table 4. – Modified wind fields and higher wind speeds (How confident is the community that wind speeds will increase? And assuredly, this cannot be a global statement. Therefore, this language should be caveated accordingly (regionally, etc.). Para 1: Increased salinity – The aforementioned factors would cause a *decrease* in salinity. Para 2: Why? Also, cite example of where this is likely to occur Table.5: Salinity Where is salinity projected to increase? Most of this report talks about salinity declines in marine environments because of freshwater inputs? Or is this outweighed by evaporation that leads to increased salinity levels? Either way, a clearer explanation – with citation – is warranted.) Accepted. Text from IPCC used. Text revised. Accepted. Text revised. Reference is added, although the reference provided did not look at the relationship between CC and POPs. The reviews referred to are believed to satisfy the scientific backing of the statements made. Text changed to be more precise. Need a reference to change this sentence. The review by Mac Donald et al., (2005) conclusion is based on the literature available up to 2005. Mac Donald et al., 2005) is a comprehensive review of this topic, as well as UNEP/AMAP 2011 and 2012. HTAP report is not looking at the climate change effect on LRT of POPs. I checked the ARCTAS campaign, but did not find their publications. A statement from IPCC is used instead. Text revised. This is already elaborated on in 4.1.b Text revised. 13 UNEP/POPS/POPRC.8/INF/21 Source of Comment United States 14 Page Chapter 26 5.1(c) United States 28 5.1(e) United States 36 5.3(e) Comments Para 2: Not only predictions based on modeling will be relevant for the evaluation of long-range transport and climate induced effects on the transport (…but what else will be? In situ observations. Also, consider citing HTAP project again in this section. ) Long-range transport (para 1 and 2): This is all relating to one study, much more appropriate to cite and discuss the findings of the HTAP project which was an assessment of peerreviewed literature, along with some new research. Table.6 title: While intuitively true, this is a qualitative table that could really benefit from citing some literature to back up the claims. Throughout, there are scientific statements that are not backed up by references. To most appropriate characterize the science – and in still the highest degree of confidence in the guidance – a more substantial review of the scientific literature is warranted, and these studies should be cited accordingly. We note many places where such citations would be valuable. United States General United States General Given the guidance’s deep connections to the science of climate change, we would encourage that the guidance is reviewed by climate science experts to avoid any inaccuracies. United States General In quite a number of areas, there are characterizations of climate change impacts that go beyond the current state of knowledge with respect to the certainty of the causality and the definitiveness and significance of the impact(s). For example, throughout the draft report, sentences state, “Climate change will…” It is more appropriate and accurate to state, “Climate change is projected to…” We have highlighted a number of areas where this minor language change could be implemented. Response Text revised. This part is describing a study as an example of data you may come across and give guidance on how to evaluate the data against the criteria, and while doing so taking into account the cc impact. Citation added. As decided by POPRC7 the text is based on the UNEP/ AMAP 2011 report which makes predictions on climate change effects on POPs. This was a substantial review of the scientific literature available at the time (2011). All conclusions on CC and POPs are from this report. In addition several other reviews on CC impact and interactions with POPs and contaminants are used in this guidance. The references referred to in those reviews are checked as far as possible. Citations are provided. In addition IPCC report is now referred to in all places where relevant, and a short summary on CC impacts of relevance given. Three experts involved in drafting the UNEP/AMAP 2011 report and other reviews on this subject have been consulted and have given comments to the text. In addition to experts on cc from the Climate and Pollution Agency in Norway have checked the information on CC impacts. See the above response. This could be a thought for POPRC to consider after it has reviewed the guidance. Accepted, though not agreed. The statements have been checked against the findings in the IPCC report. Citations are given to make this more clear. In addition have the words "can be”, “may be” and “will be” to a large extent been replaced with "have been/ was observed" and "is predicted to/projected to" to more clearly distinguish between observed and predicted/projected effects and to make the level of certainty in the cited data/ results more clear. However it should UNEP/POPS/POPRC.8/INF/21 Source of Comment Page Chapter Comments United States General In a similar vein, many climate change impacts will vary significantly on a regional basis. This important distinction does not come through in this draft report which tends to make broader, global statements. The report could benefit by – where possible – citing specific case studies /examples / regions where these impacts are known to or projected to occur. We note several places where such insertions would be valuable. We think the section is unnecessary because much of the information is already captured in other sections. Therefore, we suggest deleting the section in its entirety. It is redundant to summarize the scientific discussion in Chapter 4 in the first section of Chapter 5 and we therefore suggest deletion. “Will not change the POP properties” in para 3: We question whether this can be stated with such absolute certainty. We can imagine scenarios where ambient conditions (temp, humidity, etc.) may impact the biochemical properties of the POP and its impacts on organisms. Isn’t this correct? Therefore, please consider modifying the language to be less definitive. Or narrow the scope of “POP properties” to those that will not change (i.e., the molecular structure, perhaps?). This paragraph seems out of place. United States General on 5 United States General 5 United States 5 United States United States 5 7 The first two paragraphs are repetitive. We have provided edits, but we believe that the best path forward would be to entirely delete the first paragraph to reduce redundancy. United States 7 We question highlighting these criteria when the guidance document does not discuss the specific criteria in each Annex. Response be noted that many of the statements made in the text and the use of the words "can be”, “may be” and “will be” are derived directly from the UNEP/ AMAP 2011 report. More regional data on CC impact is added observed or projected in the fourth report by IPCC. Partly accepted. Text added of relevance for the review processes under POPRC. Needed to explain the solutions in the sub chapters coming. Accepted. Agreed. Climate change effects in a real-life exposure scenario can affect and modulate physico-chemical and biological processes and thereby impact the conditional expressions of intrinsic properties of POPs. The intrinsic properties that are referred to in the text, however, are not predicted to change with climate change. "POP properties" deleted and exchanged with "intrinsic properties", to make this clearer. Not agreed. But text changed to make the relevance more clear. Accepted to delete the text. Accepted. Text revised. For example, the section in the guidance document on persistence discusses Increased abiotic and photolytic degradation rates, increased microbial degradation or hampered microbial activity depending on the capacity of the microorganisms to endure climate fluctuations, and the impact of alterations in salinity. How does this result in Annex D(1)(b)(ii), “Evidence that the chemical is otherwise sufficiently persistent to justify its consideration within the 15 UNEP/POPS/POPRC.8/INF/21 Source of Comment Page Chapter Comments Response scope of the Convention,” being a strong enough criteria that is warrants being highlighted in the Conclusion chapter versus the more specific Annex D(1)(b)(i), “Evidence that the half-life of the chemical in water is greater than two months, or that its half-life in soil is greater than six months, or that its half-life in sediment is greater than six months”? The thought process of highlighting these specific elements of the Annexes is not clear. 16 United States 7 United States 7 United States 7 If specific criteria are highlighted, then the author should provide an explanation of why each measure should be given extra weight when considering the interaction between climate change and POPs. An alternative is to delete this sentence. We do not clearly understand what is being suggested in these two sentences. This could be interpreted as the guidance suggesting amending the text of the Convention; this is a matter for consideration at the COP, not the POPRC. Such a suggestion should be deleted. Additionally, it is beyond the mandate for this guidance document (POPRC-7/11). If this is not the intention, then the sentences need to be clarified. Further, we question highlighting “movement towards sustainable development” in Annex F. From our viewpoint, this appears to be selecting the most ambiguous element of the Annex and suggesting it is the most appropriate place to discuss climate change impacts, which is not a convincing recommendation. What is the author’s reasoning for selecting “movement towards sustainable development” over other elements? Text revised to be more clear. However, based on the findings in the guidance a change of the annex E and F is recommended in the text. From the possible magnitude of the climate change interactions on POPs, this needs to be more explicitly addressed in the guidance. This kind of information should be presented to the POPRC if available. The movement towards sustainable development is deleted. However, on a chemical by chemical basis, and only if chemical specific information is available. It will not be stronger criteria than "the toxicological interactions" mentioned in Annex E already. We have provided suggested text. Para 3 is redundant to what has already been stated. Not agreed. Para 4: Please see our comment above regarding the recommendation to add multiple stressers in Annex E. This would be a matter for the COP. Also, this is beyond the scope of the guidance document. Additionally, even if appropriate, this paragraph is repetitive. Not agreed. Multiple stressors is one of the key findings in the report and clearly related to CC interactions with POPs. Multiple stressors have been identified by UNEP/AMAP expert group and other reviews to be an important element when considering adverse effects of contaminants and climate change. The POPRC should take into account all matters of concern and multiple stressors could be one of these. On this basis POPRC could consider to address this in Annex E more explicitly, to ensure that this is considered when evaluating risk. UNEP/POPS/POPRC.8/INF/21 Source of Comment POPRC member Page Chapter Former POPRC member IPEN 3 IPEN 4 General IPEN 9 4.1(c) IPEN 11 4.2(c) IPEN 15 4.3(a) IPEN 18 4.5(a) Comments Response References are missing: Holoubek, I., Klánová, J., Jarkovský, J., Kohoutek, J. (2007): Trends in background levels of persistent organic pollutants at Kosetice observatory, Czech Republic. Part I. Ambient air and wet deposition 1988-2005. J. Environ. Monitoring, 9:557 – 563. Reference is added. Study on temperature and herbicide not included - describes one of the few experiments where the two impacts were investigated in experiments, so the results are experimental results and not just deductions from observations where cause and effect cannot be firmly linked Study: van Dam, J.W., Negri, A.P., Mueller, J.F., Altenburger, R. and Uthicke, S. (2012) Addictive pressures of Elevated sea surface temperatures and herbicides on symbiont-bearing foraminifera, pLoS ONE Para 2: add: as well as general management issues for its wate phase, for example, possible disposal in landfill susceptible to water incursion. Some references such as Blais et al., 2007, Krümmel et al., 2003 are missing from the reference list Para 10: Add: Climate change may exacerbate the contamination and availability of fish and marine mammals that are essential to the diet of Arctic Indigenous people, thus profoundly affecting food security. Para 7: Delete: The extreme flood event has been suspected to be a result of climate change in Central Europe Add: This is an example of the type of extreme flooding event that may increase in frequency with climate warming Para 3: “For POPs of high persistence like PCB and PFOS an increase of the environmental temperature would have insignificant effect” Not sure I understand the rationale for this statement, probably needs another explanatory sentence`? Para 3: Add: Melting sea ice may pose a particular threat to the species-rich marine communities of the ice edge polnyas, as stored reservoirs of POPs are mobilized directly into this fragile environment. Declining sea ice may also increase atmospheric loading to ice-free ocean waters. The 2009 AMAP report raises the concern, for example, that in a warmer Arctic there will be increase loading of endosulfan from the atmosphere to ice-free ocean surfaces. Accepted. Text added. Not accepted. Seems out of place in this para. References are added. Need a reference to include this statement. Partly agreed. Text from IPCC reports added on this matter. Agreed. Text changed. Partly accepted. Text on endosulfan has been added. Need a reference to include the statement on polnyas. 17 UNEP/POPS/POPRC.8/INF/21 18 Source of Comment IPEN 26 5.1(B) IPEN 37 6.2(a) IPEN 39 6.3(b) IPEN 39 6.3(b) Page Chapter World Chlorine Council General World Chlorine Council General World Chlorine Council General Comments Para 4: “However, it should be taken into account that the increase of a substance in organisms is not in itself always an indicator of an increase in bioaccumulation” The sentence may need more of an explanation Table.7: it would be very useful for POPRC members to at a glance known whether an impact should be considered under each of the Annexes including F. e.g. impacts on assessing costs including environmental and health costs of control measures and alternatives assessments are affected by climate change effects. Para .7: Add; Are the tested species including and sex Add: How can the impacts including additive/synergistic impacts of real world exposure be incorporated into the method? Para 9: Add; number of “expert judgments” • As the understanding of climate change as well as its potential effect on the POPRC’s work is in its initial stages, it seems useful to apply a stepwise approach, as proposed. • It is well established that changes in climate over time may cause temperature rises and decreases. Even for the last decades there are different views on whether the temperature has risen, stayed steady or even decreased. Therefore the report should provide guidance for temperature increases and for decreases on potential effects on POP assessment. • The report makes a useful step from the UNEP/AMAP 2001 report towards guidance, but the key element which still needs to be developed is quantification of the various possible effects. For example, under ‘Bioaccumulation’ 5.2.2. , 2nd paragraph, salinity changes are mentioned. In order to make such elements useful for POPRC’s evaluation work it would be necessary to indicate what the suggested changes would mean in a quantitative way. Only then it can be established whether the element is of relevance in relation to the POP criteria (in this case bioavailability-bioconcentration) or whether this is negligible. Response Accepted. Text deleted. Noted. However, the relevant information is given in chapter 5. Table is deleted. Agreed. Text added. Accepted. Noted. The document is based on the observations and projections by IPCC. The text has been changed to make this clearer. The uncertainties and ranges of changes that may have an impact will be different for every substance, impact, scientific test/observation and region, and even more complex than the estimation of climate change impacts done by IPCC. At this stage we do not know which substance that will be nominated. On this basis quantifications of the various possible effects will not be possible to do on a general basis. This has to be evaluated chemical by chemical and based on documented scientific findings with uncertainties and ranges of change given in the scientific results. POPRC should be able take into account any uncertainties or ranges of change given in the specific data presented on CC impacts on a specific substance, derived from laboratory studies or field experiments/observations. Since the evaluation of uncertainties or ranges of change will not be different from evaluation of uncertainties and ranges in other data presented to POPRC in UNEP/POPS/POPRC.8/INF/21 Source of Comment Page Chapter Comments Response the past evaluations. The guidance underlines that any predicted or observed effects should be considered on a case-by-case basis (i.e. chemical per chemical) using what is available of data for the specific substance. The uncertainties or ranges given in the scientific data is then also included in the evaluation, in a weightof-evidence approach, as has currently been the practice of POPRC in the past. World Chlorine Council General • It would be useful to have some well documented case-studies providing thoroughly evaluated evidence on climate related quantitative effects on either the screening criteria or the Annex E type of evidence. This is made clearer in the text. Noted. There are several reviews and studies on this matter that are included in the guidance. 19