AMIT THUSU

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Summary of Public call for Inputs on PoA
Workshop on Programme of Activities under the
Clean Development Mechanism Challenges and the
Road Ahead

• Bonn, 7- 8 May 2011

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CDM - Programme of Activities
Background- Work on PoAs Call for public inputs
on Programme of Activities (PoA)

• Executive Board, at its 59th meeting, agreed to
  launch a call for public inputs on programme of
  activities (PoA) from 18 February 2011 until 18
  March 2011, to seek comments on issues associated
  with the development and scaling-up of PoAs and
  barriers faced. In addition to expressing views
  regarding the implementation of paragraph 4 of
  decision 3/CMP.6, the Board specially seeks for
  inputs, in the above context, on the following
• (a) What are the possible alternative concepts
  for a PoA?
• (b) What are the barriers in the current rules?
• (c) What are the rules that are not existing or
  are missing and should be there?
• A total of 19 inputs were received publicly
  available on www.unfccc.int
• Summary of the call for inputs Annex 7 of the
  annotations to the agenda/ EB60.

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CDM - Programme of Activities
Call for Inputs Total of 19 inputs received
Overview of the Submitters
List of Organisations/submitters of Public Inputs on PoA (18 February -18 March 2011) List of Organisations/submitters of Public Inputs on PoA (18 February -18 March 2011) List of Organisations/submitters of Public Inputs on PoA (18 February -18 March 2011) List of Organisations/submitters of Public Inputs on PoA (18 February -18 March 2011)
S.No. Name of the Submitter Organisation Intrested in Attending Workshop
1 Baroda Indonesia Baroda Indonesia  
2 Sumit Barat    
3 Foo Siew Theng Gen Power  
4 Ambachew F. Admassie    
5 Lara Olsen Cool nrg Carbon Investments Pty Ltd Yes
6 Ms. Chisako URAYAMA IInstitute for Global Environmental Strategies (IGES) Yes
7 Vikas Menghwani Emergent Ventures India pvt. Ltd.  
8 Jiwan Acharya Asian Development Bank  
9 Mysore Raghavendra    
10 - DNA of Spain Yes
11 Rajesh R. Madiwale Thermax Sustainable Energy Solutions Ltd  
12 Werner Betzenbichler DoE/AIE Forum  
13 Gareth Phillips Project Developers Forum  
14 Henry Derwent/Kim Carnahan IETA  
15 Adriaan Tas Carbon Africa Limited Yes
16 Klaus Oppermann World Bank Yes
17 Ole Meier-Hahn Bridge Builders UG Yes
18 Naoki Experts Ltd. Climate Experts Ltd./ PEAR Carbon Offset Initiative Ltd.  
19 Mr. Rainer Winter/ Jun Wang TUV Nord Yes

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CDM - Programme of Activities
Overview of Main Comments/Issues raised

• Comments are rather critical, with most
  commentators showing willingness to scale-up the
  existing concept rather than develop a new
  alternative concept.
• Most of the comments are related to the issues on
  additionality, DoE liability, eligibility
  criteria for CPA Inclusion, DNA and LoA, approval
  for application of multiple methodologies.
• Some of the comments are related to the issues on
  requirement of new rules and procedures on PoA
  such as extension of micro scale additionality to
  PoAs, sampling guidance, post registration
  changes to PoAs
• Other comments are related to the issues on
  frequency of issuance requests, allowing same
  DOEs work on CPA inclusion as well as
  verification and registration fee calculation for
  multi-country PoAs (e.g. LDCs)
• Other comments are related to the infrastructure
  and management issues on lack of IT processes and
  single dedicated contact person for PoAs.
• Some comments are related to lack of capacity
  development on PoAs particularly to CMEs and CPA
  implementers
• Some comments are on extension of PoA framework
  to NAMAs

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CDM - Programme of Activities
COMPARISON 2011 Vs 2008

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CDM - Programme of Activities
Feedback and Prioritize POA Issues What are the
barriers in the current rules? (1)


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CDM - Programme of Activities
What are the barriers in the current rules? (1)

• Additionality
• Allow Investment analysis and small scale
  additionality guidelines to be applicable to PoAs
  
• Clarity on Additionality for Policy based PoAs

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CDM - Programme of Activities
Feedback and Prioritize POA Issues What are the
barriers in the current rules? (2)


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CDM - Programme of Activities
What are the barriers in the current rules? (2)

• Application of methodologies to PoAs
• Approval for Application of Multiple
  Methodologies is discouraging due to additional
  delay and process of application needs to be
  detailed
• Multiple versions of PoAs due to revision of
  methodologies is a barrier
• Application of Multiple Technologies/Baselines
• Suggestions
• Use of default/ standardized emission factors,
  such as electricity grid emission factor would
  contribute to improve the opportunities for PoAs,
  particularly in LDCs.

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CDM - Programme of Activities
Feedback and Prioritize POA Issues What are the
barriers in the current rules? (3)


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CDM - Programme of Activities
What are the barriers in the current rules? (3)

• CPA inclusion to PoA
• Currently CPA inclusion form to be filled-in by
  the DOE during CPA validation indicates checking
  almost all the major CDM parameters/issues (e.g.
  consistency/integrity, internal quality control
  aspects, additionality, emission factors).
• The lack of guidance for CPA inclusion into the
  PoA results in an overly cautious approach by the
  DOEs
• Suggestions
• - Provide guidelines for the defining the
  eligibility criteria, including also a
  sub-section in the PoA-DD on how the DOE is to
  judge whether the criteria are met.

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CDM - Programme of Activities
Feedback and Prioritize POA Issues What are the
barriers in the current rules? (4)


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CDM - Programme of Activities
What are the barriers in the current rules? (4)

• Designated Operational Entity Liability
• Perception that currently the liability is open
  ended and infinite and can be triggered at any
  point during lifetime of PoA and this creates
  unmanageable risk.
• High transaction costs are due to full liability
  and full checking
• Gross negligence is by no way applicable to
  situations where individual CPAs have not been
  scrutinized in verification activities according
  to a documented sampling plan
• Suggestions
• - Introduce time limit to liability, option of
  sharing liability, liability be limited to
  fraud/gross willful misconduct by DoE CMEs and
  limit the scope of reviewing included CPAs

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CDM - Programme of Activities
Feedback and Prioritize POA Issues What are the
barriers in the current rules? (5)




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CDM - Programme of Activities
What are the barriers in the current rules?(5)

• DNA and LoA Issues
• DNA face difficulties in evaluating sustainable
  development as LoA is not required for CPA
  inclusion require sampling approach here as
  well
• Consequences of post registration LoA withdrawal
  or revocation for one or multi-country PoA
• Some LoA that requires to mention emission
  reduction ex-ante

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CDM - Programme of Activities
Feedback and Prioritize POA Issues What are the
rules that are not existing or are missing and
should be there?



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CDM - Programme of Activities
What are the rules that are not existing or are
missing and should be there?

• New rules/procedures for PoA
• Template for Monitoring Report for a PoA
• Guidance on Materiality
• Applicability of the existing rules to programme
  of activities
• Explicitly state which existing CDM rules apply
  to PoAs.
• Revision of documentation due to inconsistency
  between PoA-DD and CPA-DD
• Revision of VVM to make it more applicable to
  PoAs and maintain consistency
• Other Issues
• Clarity on the registration fee calculation in
  the case of multi-country PoA that includes both
  LDCs and non-LDCs.
• Allow DoEs performing CPA inclusion to carryout
  verification

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CDM - Programme of Activities
Executive Boards Decision EB60 Work on
Programme of Activities (PoA)

• Clarifications provided (EB60/ Annex 26)
• Priorities was decided by the Board (EB60/ Annex
  27)

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