“Workshop on PoA: Challenges and Road Ahead” Session 2: Challenges in implementation of PoA policy and procedures - Experiences and challenges from the perspectives of a DOE DOE/AIE Forum | Werner Betzenbichler | Bonn, May 2011
Topics Existing Barriers Consequences Focus of DOE assessments
Existing Barriers (for DOEs) Ambiguous guidance on additionality assessment (EB-60 was helpful) VVM gives some “liberty”: However there are a number of requirements unique to PoAs for which additional instructions are provided below (2 paragraphs), the precise extent of validation required in each of these areas will need to be determined by the DOE based on the type or PoA being validated. bad experience (once bitten, twice shy) Limited DOE competition due to varying interpretation of required minimum efforts Incalculable risks due to erroneous inclusion issue lead to full assessment of all CPAs and to increased transaction cost Longwinded, costly and questionable procedure for reviewing erroneous inclusion Who should detect and report such cases?
Consequences by these barriers Few incentives to give momentum to further business development Small amount of trained resources lowers speed in gaining experiences Extra discussions on liability when closing contracts Time-demand in validations Incalculable risks prioritize an “observer status”, awaiting further clarity No real cost reduction for project participants as originally intended
Focus of DOE assessments / where it is Validation − Additionality of the first CPA − Monitoring especially sampling − Standard CDM requirements − Forwarding issues to inclusion Inclusion: − Minimizing risk of erroneous inclusion by complete checks Verification: − No reported experiences
Focus of DOE assessments / where it should be the correct choice and application of the methodology the appropriateness and completeness of eligibility criteria the system and internal checks for CPA inclusion, its implementation and its effectiveness; the system for monitoring of the required parameter, its implementation and its effectiveness; the appropriate implementation of the PoA with regard to technological aspects; the system for internal verification, its implementation and its effectiveness; a confirmation of the amount of CERs that can be certified at a reasonable level of assurance taking into account the fact that the result is based on the assessment of samples
Werner Betzenbichler Chair of the DOE/AIE Forum on behalf of TÜV NORD Designated Operational Entities and Independent Entities Association ▪