AMIT THUSU UNFCCC Secretariat SDM programme Summary of Public call for Inputs on PoA Bonn, 7- 8 May 2011 Workshop on Programme of Activities under the.

AMIT THUSUUNFCCC SecretariatSDM programme

Summary of Public call for Inputs on PoA

Bonn, 7- 8 May 2011

Workshop on Programme of Activities under the Clean Development Mechanism: Challenges and the Road Ahead

Executive Board, at its 59th meeting, agreed to launch a call for public inputs on programme of

activities (PoA) from 18 February 2011 until 18 March 2011, to seek comments on issues

associated with the development and scaling-up of PoAs and barriers faced. In addition to

expressing views regarding the implementation of paragraph 4 of decision 3/CMP.6, the Board

specially seeks for inputs, in the above context, on the following:

(a) What are the possible alternative concepts for a PoA?

(b) What are the barriers in the current rules?

(c) What are the rules that are not existing or are missing and should be there?

A total of 19 inputs were received publicly available on www.unfccc.int

Summary of the call for inputs: Annex 7 of the annotations to the agenda/ EB60.

Background- Work on PoAs

Call for public inputs on Programme of Activities (PoA)

CDM - Programme of Activities

2


Call for Inputs : Total of 19 inputs received

Overview of the SubmittersList of Organisations/submitters of Public Inputs on PoA (18 February -18 March 2011)

S.No. Name of the Submitter OrganisationIntrested in Attending Workshop

1 Baroda Indonesia Baroda Indonesia

2 Sumit Barat

3 Foo Siew Theng Gen Power

4 Ambachew F. Admassie

5 Lara Olsen Cool nrg Carbon Investments Pty Ltd Yes

6 Ms. Chisako URAYAMA IInstitute for Global Environmental Strategies (IGES) Yes

7 Vikas Menghwani Emergent Ventures India pvt. Ltd.

8 Jiwan Acharya Asian Development Bank

9 Mysore Raghavendra

10 - DNA of Spain Yes

11 Rajesh R. Madiwale Thermax Sustainable Energy Solutions Ltd

12 Werner Betzenbichler DoE/AIE Forum

13 Gareth Phillips Project Developers Forum

14 Henry Derwent/Kim Carnahan IETA

15 Adriaan Tas Carbon Africa Limited Yes

16 Klaus Oppermann World Bank Yes

17 Ole Meier-Hahn Bridge Builders UG Yes

18 Naoki Experts Ltd. Climate Experts Ltd./ PEAR Carbon Offset Initiative Ltd.

19 Mr. Rainer Winter/ Jun Wang TUV Nord Yes

Comments are rather critical, with most commentators showing willingness to scale-up the existing concept rather

than develop a new alternative concept.

Most of the comments are related to the issues on additionality, DoE liability, eligibility criteria for CPA Inclusion,

DNA and LoA, approval for application of multiple methodologies.

Some of the comments are related to the issues on requirement of new rules and procedures on PoA such as

extension of micro scale additionality to PoAs, sampling guidance, post registration changes to PoAs

Other comments are related to the issues on frequency of issuance requests, allowing same DOEs work on CPA

inclusion as well as verification and registration fee calculation for multi-country PoAs (e.g. LDCs)

Other comments are related to the infrastructure and management issues on lack of IT processes and single

dedicated contact person for PoAs.

Some comments are related to lack of capacity development on PoAs particularly to CMEs and CPA

implementers

Some comments are on extension of PoA framework to NAMAs

Overview of Main Comments/Issues raised


4


ANALYSIS OF PUBLIC INPUTS - PoA

53

26

42

42

26

47

37

58

47

- 10 20 30 40 50 60 70 80 90

Additionality

Methodologies

CPA Inclusion

DOE Liability

DNA and LoA Issues

Applicability of Existing CDM Rules to PoA

Other Issues

No need of Alternative concept to PoA

Requirement of new rules/procedures for PoA

key

issu

es

% response to key issues

2008 2011

5

COMPARISON: 2011 Vs 2008


ADDITIONALITY

30%

40%

22%

4% 4%

Allow Start date of CPA before Validation

Clarify PoA or CPA level Additionaity

Alllow micro-scale additionality for PoA

PoA Start date not defined

Pending Procedures and Guidance

Feedback and Prioritize POA Issues

What are the barriers in the current rules? (1)

Additionality

• Allow Investment analysis and small scale additionality guidelines to be applicable to PoAs

• Clarity on Additionality for Policy based PoAs






METHODOLOGIES

53%

8%

8%

15%

8%8%

Application of Multiple Methodologies

Current Framew ork not applicable to City w idePoAs

Monitoring Procedures

Revise Debundling Criteria

Revision of methodology on hold or w ithdraw n

No guidance on how to assess the impact ofmandatory law on baseline emissions

8

Application of methodologies to PoAs

• Approval for Application of Multiple Methodologies is discouraging due to additional delay and process of application needs to be detailed

• Multiple versions of PoAs due to revision of methodologies is a barrier

• Application of Multiple Technologies/Baselines

• Suggestions:

• Use of default/ standardized emission factors, such as electricity grid emission factor would contribute to improve the opportunities for PoAs, particularly in LDCs.




CPA INCLUSION

22%

56%

22%Definition of eligibility criteria for CPA inclusion

Clarify the scope of the eligibility criteria forCPA inclusion

Impact of erroneous inclusion of a CPA onother CPAs/PoA

10



CPA inclusion to PoA

• Currently CPA inclusion form to be filled-in by the DOE during CPA validation indicates

checking almost all the major CDM parameters/issues (e.g. consistency/integrity, internal

quality control aspects, additionality, emission factors).

• The lack of guidance for CPA inclusion into the PoA results in an overly cautious

approach by the DOEs

• Suggestions:

- Provide guidelines for the defining the eligibility criteria, including also a sub-section in

the PoA-DD on how the DOE is to judge whether the criteria are met.




DOE LIABILITY

31%

32%

14%

9%

14%Unlimited Liability (time, quantity, no fault)

Revision of existing procedures

High transaction costs

Sharing liability betw een DOE and CME

Subjective Assessment of Eligibility Criteria

12



Designated Operational Entity Liability

• Perception that currently the liability is open ended and infinite and can be triggered at any point during lifetime of PoA and this creates unmanageable risk.

• High transaction costs are due to full liability and full checking

• Gross negligence is by no way applicable to situations where individual CPAs have not been

scrutinized in verification activities according to a documented sampling plan

• Suggestions:

- Introduce time limit to liability, option of sharing liability, liability be limited to fraud/gross

willful misconduct by DoE & CMEs and limit the scope of reviewing included CPAs




DNA & LoA ISSUES

59%33%

8%

Post Registration addition of parties

Diff iculties in evaluating sustainabledevelopment for CPA inclusion

DNA approval of voluntary participation

14



DNA and LoA Issues

• DNA face difficulties in evaluating sustainable development as LoA is not required for CPA inclusion – require sampling approach here as well

• Consequences of post registration LoA withdrawal or revocation for one or multi-country PoA

• Some LoA that requires to mention emission reduction ex-ante

What are the barriers in the current rules?(5)



REQUIREMENT OF NEW RULES/REVISION OF PROCEDURE

60%

40%

Sampling guidance not sufficient or notavailable

Revision of existing procedures -Inclusion of CPAs (not related toLiability)

16


What are the rules that are not existing or are missing and should be there?

New rules/procedures for PoA

• Template for Monitoring Report for a PoA

• Guidance on Materiality

Applicability of the existing rules to programme of activities

• Explicitly state which existing CDM rules apply to PoAs.

• Revision of documentation due to inconsistency between PoA-DD and CPA-DD

• Revision of VVM to make it more applicable to PoAs and maintain consistency

Other Issues

• Clarity on the registration fee calculation in the case of multi-country PoA that includes both LDCs and non-LDCs.

• Allow DoEs performing CPA inclusion to carryout verification

What are the rules that are not existing or are missing and should be there?


Clarifications provided (EB60/ Annex 26)

Priorities was decided by the Board (EB60/ Annex 27)

Executive Boards Decision – EB60

Work on Programme of Activities (PoA)


18

AMIT THUSU UNFCCC Secretariat SDM programme Summary of Public call for Inputs on PoA Bonn, 7- 8 May 2011 Workshop on Programme of Activities under the.

Documents

poa issues

current rules

poa results

poa bonn

poas approval

poas clarity

public inputs

activities feedback