Assessing seriousness of CDM consideration

DOES IMPLEMENT OWN RULE TO ASSESS SERIOUSNESS OF CDM CONSIDERATION

Robert Dornau, Director Climate Change Programme, SGS and Vice Chair DOE Forum.

One of the major reasons for a rejection of a CDM project by the CDM Executive Board is that the project fails to provide sufficient evidence that the benefits of the CDM were seriously considered by the project developer before the start of the project.

In order to address this, major DOEs (SGS, DNV, TUV Süd, TUV Rheinland) are now implementing a new approach. This approach was agreed in the last DOE forum meeting held in April 2008. DOEs agreed that a good indicator for the seriousness of CDM consideration is the time gap between start of the project and submission of a project for validation. This time gap should not be more than 12 months. The same requirement is already enforced by the Voluntary Carbon Standard.

As of July the following conditions have to be met for a project to be accepted for validation:

Within 12 months after start date of the project, the Project Participant (or an entity nominated by the PP to do so) has to either:

• Submit project for validation to a DOE (using an approved methodology); or
• Submit a new methodology for approval by the EB via a DOE; or
• Submit letter to a DOE that the project is waiting for approval of a new Methodology.

Start date of the Project is defined to be the earliest of financial closure, ordering of major equipment, construction permit (if reasonable proof) or start of construction

If the above is not followed, it is assumed that the CDM was not seriously considered and the project is not really depending on the CDM benefits in its implementation.

The following exception applies: A project that has started implementation can be considered for validation, if it had to be stopped because of a change in financing conditions and was not able to secure new financing (without CDM) for a period of 12 months.