UNFCCC secretariat Karla Solís, Programme Officer Introduction to current decisions: Recurring issues Project and Entity Assessment Unit CDM Registration Team Bonn, 11 March 2011

Outline of the presentation Assessment at registration stage: Additionality: Prior consideration Investment analysis Baseline identification Assessment at issuance stage: Changes of PPD

Prior consideration issue: Real and continuing actionsRegistration Requirements: VVM v1.2, paragraph 102.b …(b) Reliable evidence from PPs that must indicate that continuing and real actions were taken to secure CDM status for the project in parallel with its implementation. Evidence to support this should include, inter alia, contracts with consultants for CDM services, ERPAs or other documentation related to the sale of CERs, evidence of agreements or negotiations with a DOE for validation services, submission of a new methodology to the CDM EB, publication in newspaper, interviews with DNA, correspondence with the DNA/UNFCCC. EB 49, Annex 22, paragraphs 7, 8. b: …(b) the gap between documented evidence is greater than 2 years and less than 3 years, the DOE may validate that continuing and real actions were taken to secure CDM status for the project activity and shall justify any positive or negative validation opinion based on the context of the evidence and information assessed;…

Example of an assessment: The prior consideration was based on a CDM letter of intent between the PP and CDM consultancy, 11 Sep The starting date is 21 October 2004 when the construction contract was signed. The continuous actions were confirmed through the CDM consultancy contract (3 Jun 2007) and validation started on 8 January The PDD/VR do not show CDM actions after the project starting date and the start of the CDM consultant. It is not clear how the DOE validated the continuous and real actions taken to secure CDM during the gap of almost 3 years between the project start date and the CDM consultancy contract. Prior consideration issue: Real and continuing actionsRegistration

Requirement: VVM, v1.2, paragraph 111 To verify the accuracy of financial calculations carried out for any investment analysis, the DOE shall: (a) Conduct a thorough assessment of all parameters/assumptions used in calculating the relevant financial indicator, and determine the accuracy and suitability of these parameters using the available evidence and expertise in relevant accounting practices; (b) Cross-check the parameters against third-party or publicly available sources, such as invoices or price indices; … Example of an assessment: The investment costs assumed in the IRR calculation is based on a feasibility report, finalised in April These costs are validated as follows: The total investment costs of 30.4 million US$ (1,700 US$/kW, 21 MW hydro turbine) was compared to three similar (20-36 MW capacity) registered CDM projects in the region with a range of 1,100-1,250 US$/kW. The DOE justified that the higher unit investment cost of the proposed project is because it has a long dam (287.02m). However the DOE did not cross-check the investment costs with a third party source. Investment analysis: Input valuesRegistration

Baseline identification: ACM0001Registration Requirement: VVM, v1.2, paragraph 85 The DOE shall determine whether all applicable CDM requirements have been taken into account in the identification of the baseline scenario for the proposed CDM project activity, including relevant national and/or sectoral policies and circumstances. Drawing on its knowledge of the sector and/or advice from local experts, the DOE shall confirm that all relevant policies and circumstances have been identified and correctly considered in the PDD, in accordance with the guidance by the CDM Executive Board. Example of an assessment: ACM0001: The baseline is continuation of venting the landfill gas. The DOE validated the implementation of the existing regulation (introduced in January 2006) to flare landfill gas is not applied in the country. The validation was carried out by a letter from the flaring technology supplier which confirms that the regulation is not being implemented due to lack of monitoring/supervising procedures. However, it is not clear if the approach of this validation is appropriate.

Project implementation as per the PDD Issuance Requirements: VVM paragraph The DOE shall identify any concerns related to the conformity of the actual project activity and its operation with registered PDD The DOE shall verify by an on-site visit all physical features… and that the project participants has operated the project activity as per the PDD… In case of any changes, a notification or request for approval should be submitted to the Board. Example of an assessment: Changes of biomass used in the thermal plant can affect additionality due to price changes in biomass types. [AMS-I.C and ACM0006] Changes of the capacity, number of units and configuration of equipments to be installed E.g. wind turbines Plant load factor as compared to estimate in PDD. E.g. biomass plants.

References Prior consideration Additonality tool: tool-01-v5.2.pdfhttp://cdm.unfccc.int/methodologies/PAmethodologies/tools/am- tool-01-v5.2.pdf Guidelines on investment analysis, v3: Guidelines on barrier analysis Validation and Verification Manual Methodologies:

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