Milena Roudná, National UNEP/GEF Project Coordinator, Czech Republic

Recommendations for the changes:
Annex 1 – I. Context, page 6, ad 5, add the following or correct (in bold):
This draft Strategic Plan and  …have been prepared on the basis of  ….decisions taken ….at its last four meetings, and through general discussion and comments received.
II., page 7, ad 6  – last sentence – formulation of strategic objectives need to be in accordance with those in the Table (pages 9-19) and reformulated as follows:
The focal areas underlying the five strategic objectives are as follows: 1. Implementation of the Protocol; 2. Capacity Building; 3. Outreach and Cooperation; 4. Compliance and Review; 5. Information Sharing.
Ad 7, second bullet: The operational objectives …..in order to implement impacts
Ad 8, in the last sentence delete for example: Some of the actions will be undertaken by Parties …
III., ad 10, (a):  …. MPO decisions into their national/regional frameworks
(i.e. to use corresponding terminology)
c) – delete text in the parenthesis: Parties ……required information to the BCH
IV. , page 8 , ad 12 – last sentence, last line (to be text quite clear): 
…and technical/capacity building support, as well as of two programme assistants
V., page 8, ad 13, last but one sentence:
Information will be drawn mainly from national reports and from other available sources to generate the data necessary for the analysis.
i.e. delete among other things

Draft Elements of the Strategic Plan – Table, pp. 9 - 19

Strategic Objective – Focal Area 1 (page 9)
Further Guidance Development – this is more a tool how to reach strategic objective not strategic objective as such – recommendation (in line with content):
Implementation of the Protocol  (see  page 7, II. Ad 6)

Expected Impacts
P. 13 – Expected Impacts arrange in a logical way, as follows (and complete add 2):
(1) Increased safety in …
(2) Effective and efficient regulatory, administrative and monitoring frameworks….
(3) Necessary mechanisms put in place ….
(4) More transparent and expeditious decision-making
(5) Full use of information exchange system
P. 19 - Expected Impacts arrange in a logical way, as follows:
(1) Transparency in the development …
(2) Increased compliance …
(3) Informed decision making
(4) Enhanced public awareness of biosafety

Operational Objectives
Focal Area 1, p. 9-12  - arrange in a logical way, as follows:
1.1 Scientific and technical advice
1.2 LMOs or traits that may have …
1.3 Risk assessment and risk management
1.4 Handling, transport, packaging and identification
1.5 Transit, contained use …
1.6 Liability and redress
Focal Area 2, p. 13-16 (proposed changes p. 15-16) - arrange in a logical way, as follows:
2.1 Coordination and support
2.2 National Biosafety Framework
2.3 Risk assessment and risk management
2.4 Handling, transport …
2.5 Liability and redress
2.6 Information sharing
2.7 Biosafety education and training
2.8 Public awareness …

Outcomes
P. 11:
Each Party takes ….necessary to implement the rules and procedures on liability and redress at national level
i.e. delete , at the domestic level,
P. 13:
Compare bullet 3rd and bullet 5th – recommendation to delete bullet 3: Parties have adequate …
Similar appears among Indicators – p. 13 – last but one bullet: Number of Parties that have predictable and reliable funding ….
Moreover, what means predictable financial resources, especially in our period and current economic situation?  Who can guarantee them?
P. 16:
Outcomes related to 2.7 - arrange in a logical way, as follows:
(1) Increased access to information …
(2) Tools to facilitate implementation ..
(3) Information on BCH …
P. 18:
Outcomes related to 4.2 – second bullet:
The Protocol, including its procedure and annexes, is amended if new challenges are ….
i.e. replace adapted by amended
delete by Parties as the precise rules of procedure exists under which conditions Protocol can be amended  - COP/MOP role etc. not Parties as such ?

Indicators
P. 11 – second bullet:
Percentage of Parties …having in place national administrative … (terminology)
P. 13  predictable and reliable funding  ?
P. 14 – second bullet related to 2.3:
Number of risk assessment ….that are in compliance with the Protocol
P. 15 – second bullet related to 2.5:  Number …in the field of liability and redress
Third bullet related to 2.6:
Number of Parties authorities with a network of biosafety and communication experts –
Questionable, not too realistic
P. 16 – second bullet related to 2.7: Amount of traffic to the BCH … ? – see as well p. 19
P. 17 – second bullet related to 3.3:
Percentage of Parties that have in place national communication strategies on biosafety …-
Maybe desirable, but not too realistic – such strategy can be a part of National Biosafety Strategy or of other related national strategic documents, depending on each Party conditions/situation.
P. 18
Second bullet related to 4.2:
Number of Parties …..with the aim to meet new biosafety chalanges (delete of adapting to new).
4th bullet to 4.2:
Number of subsidiary bodies  …
Can this be really an indicator of success ? efficiency, synergy …?