Understanding CDM Methodologies - SuSanA

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