Understanding CDM Methodologies - SuSanA
Understanding CDM Methodologies - SuSanA
Understanding CDM Methodologies - SuSanA
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Role of DOEs<br />
– Absence of<br />
Accreditation,<br />
Validation and<br />
Verification<br />
Standards<br />
DNAs check<br />
Sustainable<br />
Development<br />
Impacts<br />
DOEs validate 79 proposed <strong>CDM</strong> projects and verify emission reductions 80 . They<br />
have to show that they are free of conflict of interest regarding the project<br />
participant 81 . To get accreditation as a DOE, companies or institutions have to<br />
fulfil a number of requirements listed in, including the need to have insurance<br />
cover 82 , a management structure with quality assurance procedures 83 and<br />
documented structures which safeguard impartiality 84 . As project participants<br />
can freely select among accredited DOEs 85 , an intense competition for<br />
getting validation and verification assignments has developed between<br />
DOEs. In addition, project participants not only select DOEs but contract and<br />
remunerate them for their services. Some have argued for a revision of this<br />
relationship because of a potential conflict of interest – where DOEs may<br />
have difficult rejecting validation of projects as they could lose clients whose<br />
projects did not achieve validation. There are no standards for validation and<br />
verification (see section 2.2.3). No liability other than the risk of losing the<br />
accreditation exists for mistakes in validation. DOEs are liable for “excess<br />
CERs” issued due to significant deficiencies in verification found in an EBmandated<br />
review by another DOE 86 ; however no DOE has been fined so far.<br />
Countries can only participate in the <strong>CDM</strong> if they have ratified the Kyoto<br />
Protocol 87 . Countries have to specify a Designated National Authority<br />
(DNA) for project approval 88 . Annex B countries can use CERs only if they<br />
fulfil the requirements of Article 5 and 7 of the Kyoto Protocol regarding their<br />
emission inventory and specification of their emissions budget 89 .<br />
Companies and public entities have to be authorized to participate in<br />
<strong>CDM</strong> projects 90 ; this is usually done within the text of the approval letter<br />
by the DNA. They can only buy and sell CERs if the authorizing country is<br />
allowed to use CERs.<br />
Figure 1: <strong>CDM</strong> institutions<br />
accredits<br />
elects<br />
COP/MOP<br />
EB<br />
supervises<br />
support,<br />
recommend<br />
DOE<br />
MP<br />
A&R –<br />
WG<br />
AP, AT<br />
SSC –<br />
WG<br />
RIT<br />
UNFCCC<br />
Secretariat<br />
79<br />
Annex to decision 3/CMP.1, para 27 (a)<br />
80<br />
Ibid., para 27 (b)<br />
81<br />
Ibid., para 27 (d)<br />
82<br />
Appendix A to decision 3/CMP.1, para 1 (c)<br />
83<br />
Ibid., para 1 (g)<br />
84<br />
Ibid., para 2 (a) (i)<br />
85<br />
Annex to decision 3/CMP.1, para 37<br />
86<br />
Ibid., para 22<br />
87<br />
Ibid., para 30 and 31 (a)<br />
88<br />
Ibid., para 29. The preamble of 17/CP.7 had specified that sustainable development impacts of a proposed <strong>CDM</strong><br />
project are only checked by the host country.<br />
89<br />
Ibid., para 31. These requirements have been elaborated in decisions 12, 13, 15, 19, 20 and 21/CMP.1<br />
90<br />
Ibid., para 33<br />
15