1. 7th Joint Coordination Workshop “Improving efficiency in the operation of CDM” - DOE Viewpoints DOE/AIE Forum | Werner Betzenbichler | March 2011

2. Topics to be touched DOEs perspective on the recent changes Positive and negative impacts Further improvements needed

3. Which factors are most important when defining efficiency? Speed Quality Comparability Fairness / Equal Treatment Integrity Reliability

4. Remember the Objectives A market-based mechanism for a clean development Market requires calculable conditions (costs, return, time horizon, legislation) on project basis A clean development should deliver measurable results on national and global basis

5. DOEs are exposed to market conditions --> need for calculable conditions Own costs (time efforts, required human resources, other costs) Return --> marketable prices Time horizon --> dispatching of resources, receiving of income Legislation --> liabilities and/or penalties, business license / accreditation Interference with other businesses

6. Impacts of recent changes Changes in Procedures for Completeness Checks − More predictability of time schedule of first round (+) − Lower likelihood for reviews on minor issues (+) − No effective time reduction in case of identified issues, rather an extension (-) − Continuing dependence on review quality (±) − Continuing unbalanced requirements on technical expertise (±)

7. Impacts of recent changes (2) Changes in Procedures for Requests for Reviews − Reduced predictability of time schedule (-) − De-linking from EB meeting schedule (+) − Inclusion of a second opinion (+)

8. Impacts of recent changes (3) Accreditation Standard 2.0 − Improved guidance to DOEs and AT (+) − Safeguards market fairness (+) − Way to improve overall quality (+) − Reduction of available human resources (-) − Missing „permeability“ to qualify as auditor/expert for complex technical areas (-)

9. Recent deliberations Direct communication − Important to accelerate whole process − Requires clear allocation of projects with secr. over the whole registration or issuance process − Establish contact persons for projects within secr. − Establish contact persons for DOEs within secr. − Recognition of improvements with regard to DOE interaction (responses on extranet, direct interaction with AP)

10. Recent deliberations (2) PoA − Recent situation makes PoA unattractive − More responsibility (and liability) to Coordinating Entity − CPA inclusion and verification by CE, DOE assessment as it were accreditation − Procedures for erroneous inclusion at a manageable level also considering possible impacts at a reasonable ratio

11. Further improvements needed Excess liability for DOEs − Recent situation makes DOE business unattractive − Penalty and not a liability issue − Penalty depends on impact not on mistake − Penalty in addition to accreditation threats − Based on presumptions at the time of Marrakesh which may not be valid any longer

12. Further improvements needed (2) Electronic means to accelerate the process − Electronics forms e.g. for monitoring reports and verification reports (compare EU-ETS) − Completeness checks by software Harmonization of AT performance − Complaints on arbitrary interpretation of regulations − Consistency among DOEs requires consistency among ATs

13. Werner Betzenbichler Chair of the DOE/AIE Forum on behalf of TÜV NORD Designated Operational Entities and Independent Entities Association c/o BeCe Carbon Experts GmbH ▪ Bahnhofstraße 7 ▪ 85354 Freising ▪ Germany ▪ Werner.Betzenbichler@bece-experts.comWerner.Betzenbichler@bece-experts.com