Understanding CDM Methodologies - SuSanA
Understanding CDM Methodologies - SuSanA
Understanding CDM Methodologies - SuSanA
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Small Scale<br />
Thresholds over<br />
Time<br />
Crediting Periods<br />
and Early Start<br />
Projects<br />
Box 1: Changes of definitions of small-scale project thresholds over time<br />
The question of thresholds for definition maximum size thresholds for small scale<br />
<strong>CDM</strong> projects has led to repeated changes in the definition with huge impacts<br />
for project developers. Initially, the thresholds were 15 MW for renewable energy<br />
projects (type I), 15 GWh annual savings for energy efficiency projects (type II)<br />
and direct emissions of 15,000 t CO2 equivalent for other project types (type III) 19 .<br />
The threshold for type III projects immediately gave rise to a discussion 20 as the<br />
wording “both reduce anthropogenic emissions by sources and directly emit less<br />
than 15 kilotonnes” could be understood in two ways:<br />
a) CER volumes as well as project emissions have to be below the threshold,<br />
b) only project emissions have to be below the threshold.<br />
COP 8 chose the second definition 21 . Unsurprisingly, many project developers<br />
submitted type III projects with substantial annual CER volumes 22 , reaching up to<br />
several hundred thousand per year. Therefore, the EB reopened the discussion<br />
on small-scale thresholds in general 23 . Finally, COP 11 increased the threshold for<br />
type II projects to 60 GWh/year and applied interpretation a) to type III projects<br />
whose threshold was increased to 60,000 t CO 2<br />
/year 24 .<br />
CERs can only accrue from the date of registration of a <strong>CDM</strong> project for a<br />
crediting period of 10 years or for a period of three times 7 years with<br />
an update of the baseline after each interval 25 . For projects submitted for<br />
registration before 31 December 2005 that had started between 1 January<br />
2000 and 12 November 2001, CERs would accrue from the starting date 26 .<br />
The deadline has subsequently been shifted several times (see Box 2).<br />
Box 2: The snail’s pace of early start projects<br />
Quantification<br />
– Choosing<br />
Baselines and<br />
Additionality<br />
Establishment of the <strong>CDM</strong> institutions and approval of methodologies took<br />
more time than envisaged at Marrakech. When December 2005 approached,<br />
it became clear that many projects would not be able to submit a request for<br />
registration in time due to the lack of approved methodologies for many project<br />
types. Therefore, COP 11 expanded the definition of early start projects to those<br />
that had started by 18 November 2004 and submitted a new methodology or<br />
have requested validation by a designated operational entity by 31 December<br />
2005 and extended the deadline to registration by 31 December 2006 27 As even<br />
this interpretation was immediately felt to be insufficient, the EB decided that<br />
“request of validation” was to be interpreted that a PDD had been submitted<br />
to a DOE by 31 December 2005 and that the methodology submission cut-off<br />
date was 11 January 2006 28 . Finally, COP 12 extended the deadline to 31 March<br />
2007 and (incorrectly!) referred to decision 7/CMP.1 as relating to submission for<br />
registration, which obviously was equal to another extension… 29<br />
19<br />
Decision 17/CP.7, para 6 (c)<br />
20<br />
See SSC_030<br />
21<br />
Decision 21/CP.8<br />
22<br />
Sources of greenhouse gases generated by the anaerobic decay or burning of manure, agricultural waste or<br />
other organic matter waste with biomass origin.<br />
23<br />
EB24 requested the SSC WG to develop new Type III categories, that include procedures for more precise<br />
estimations of emissions reductions and requested more details on monitoring by the SSC WG 07 meeting.<br />
Later, the EB agreed to allow a 25 kt CO2eq./yr limit on annual emissions reductions for all Type III categories as<br />
an interim measure.<br />
24<br />
Decision 1/CMP.2, para 28<br />
25<br />
Decision 3/CMP.1, para 49<br />
26<br />
Decision 17/CP.7, para 12. According to the <strong>CDM</strong> glossary, the starting date is the earliest date at which either<br />
the implementation or construction or real action of a project activity begins.<br />
27<br />
Decision 7/CMP.1, para 4<br />
28<br />
EB 23, para 90<br />
29<br />
Decision 1/CMP.2<br />
11