Understanding CDM Methodologies - SuSanA

While COP/MOP has provided that Large projects can be bundled without
any limit 138 , the board has placed a limit of bundling of small-scale projects to
the overall small-scale threshold 139 .
An official glossary defines key CDM terms; it has been regularly updated but
never been subject to a COP/MOP decision.
2.2.3 Active COP/MOP guidance for the EB
Missing Validation
and Verification
Standards due
to Existence of
Validation and
Verification
Manual
Formal Adoption
of revised VVM
planned
Sometimes, COP asks the EB to work on regulatory issues that it feels
insufficiently addressed.
COP 12 asked the EB to promote quality and consistency in verification
and validation by DOEs by providing guidance to DOEs 140 , as no rule of the
Marrakech Accords provides validation and verification standards. In an
attempt to make DOE operations comparable and consistent, Det Norske
Veritas Certification (DNV) in cooperation with TÜV Süddeutschland and
KPMG had developed a Validation and Verification Manual (VVM) in 2003.
The VVM introduced the terms “Corrective Action Request” (CAR) and
Clarification Request (CL). The former shows that the DOE deems the CDM
rules be violated by the PDD, whereas the latter indicated that information
is insufficient, unclear or not transparent enough to establish whether a
requirement is met. Under the VVM, DOEs follow a validation protocol which
contains a set of 86 questions. Despite substantial changes in the PDD and
the EB practice, the VVM has not been revised so far. While most DOEs (DNV,
TÜV Süd) use the template provided by the VVM to structure the validation
report, others (SGS) have used their own structure. However, the EB was
slow to address the task given by COP after deciding that the VVM should
be reviewed and a revised version should be formally adopted after inputs by
DOEs and the general public had been solicited 141 . Until COP 13, this issue
had not been resolved.
2.2.4 Administrative decisions by EB vetted by COP/MOP
With regards to purely administrative decisions, COP/MOP essentially vets
proposals made by the EB.
Administration
Fee
EB can ask for
Corrections after
Review
The Marrakech Accords had specified that for financing of the EB and the
regulatory structure, an administration fee could be levied. On suggestion of
the EB, COP 11 accepted a fee of 0.1 $ per CER up to 15,000 CERs per year
and 0.2 $ for CER volumes above this level. The fee is collected when CERs
are issued 142 ; at registration an advance payment calculated on the average
annual issuance level forecast in the PDD is levied 143 .
The EB felt that the Marrakech Accords were too constraining regarding
the outcomes of a review of a registration or issuance request. Instead
of only allowing acceptance or rejection as a result of a review, the EB
can ask project developers to make corrections to the PDD 144 . The same
138
Ibid., para 21
139
EB 21, Annex 21
140
Decision 1/CMP.2, para 12
141
EB 32, Annex 1
142
Decision 7/CMP.1, para 37. Previously, a staggered registration fee had been levied, ranging from 5000 to
30,000 $ depending on the size of the project (EB 6, Annex 5)
143
EB 23, Annex 35, which also specifies that the advance payment is capped at 0.35 million $ in the case of
rejection, any fee above 30,000 $ will be paid back to the developer.
144
Annex II to decision 18/CP.9, para 18 (b)
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