Understanding CDM Methodologies - SuSanA

6. Conclusions
The rules of the CDM are constantly evolving through a complex interaction
between several rule-making entities. Framework rules that are stable have
been defined by the Kyoto Protocol and the Marrakech Accords. On the
other hand, the EB and its panels and working groups decide according
to the immediate requirements of the CDM process. With the increase of
submission of methodologies and CDM projects, the volume of decisions has
increased. These decisions are not presented in a clear, formal way, but as
elements in and annexes to the EB’s meeting reports as well as in occasional
guidance documents. While some case law is developing, the EB occasionally
revises or even withdraws previous decisions.
The COP serves as link between the framework level and the day-to-day
decisions. However, it is reluctant to take “technical” decisions. Sometimes,
disagreements persist between the COP and the EB, which lead to iterative
admonitions of the COP to the EB.
Over time, the EB’s requirements for application of baseline and monitoring
methodologies have been strengthened and the key determinants of
additionality testing are better understood. The consolidated additionality
tool has become the de facto standard of additionality determination.
Data used for the investment test and argumentation about barriers are
increasingly sophisticated and referencing improves.
While the monitoring plan was initially not seen as a key element of the PDD,
it has become its cornerstone. A credible, redundant management structure
for monitoring and an emphasis on choice of adequate measurement
equipment characterise good PDDs. A challenge is still an objective definition
of quality assurance and – control procedures.
One area where the EB has so far not been able to provide adequate
incentives and rules relates to validation. So far, no DOE has been suspended.
Despite increasing evidence of validator failures, the rules remain surprisingly
fluid. Even if a project is rejected, there will not be an automatic spot check
of the DOE even if DOE performance is in doubt.
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