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FIRST DRAFT OF VALIDATION AND VERIFICATION MANUAL SHOWS WAY FORWARD
By Robert Dornau, Director, Climate Change Programme, SGS
The UNFCCC Secretariat has drafted “version zero” of the Validation Verification Manual, which the EB was tasked to develop with urgency by the COP/MOP.
This draft was discussed between Designated Operational Entities (DOEs) Applicant Entities (AEs), the UNFCCC Secretariat and two EB Members (Chair and Vice Chair of the Accreditation panel) last week in Bonn.
This meeting was held in a very constructive atmosphere and helped to improve understanding of the process and required outcome.
The draft VVM, including comments made at last week’s gathering, will be discussed at the next EB meeting, which will decide the path towards a final document.
It is expected that the VVM will help the process of validation and verification in two ways. DOEs and project developers will gain a better understanding of how the EB interprets their guidance. At the same time the EB will in take into account the requirements of how auditors carry out their work.
For DOEs to be the extended arm of the EB as intended by the Marrakech Accords, it is essential that the arm and the body have the same understanding of how to interpret the requirements and how to conduct the work.
DOEs are therefore very much looking forward to more exchange with the EB as part of the development of the final VVM.
The aim of the VVM is to assure consistent quality and approach of validation and verification activities across DOEs.
Last week, DOEs and AEs flagged up the following issues: The VVM should function as a standard clearly summarizing the requirements currently spread over a number of different COP/MOP decisions in one document, with reference to additional EB guidance where applicable.
Only the accompanying EB interpretation and attached examples can ensure that both DOEs and EB interpret the standard text in the same way.
In addition, templates and tools that can be used in the validation process should help in applying a more consistent approach.
The current level of request for reviews is not sustainable. Neither for the EB nor for DOEs. Projects going for review require the attention of the most qualified staff at the DOEs.
This staff is then not available to work on current projects or advise their auditor colleagues. This tightens the bottleneck, more projects are delayed and workload and time pressure is increased.
Most requests for reviews at registration stage are raised for questions on the proof of additionality.
Additionality is an area that is not black and white, and contains many shades of grey. Making distinctions are difficult, and obviously one can come to different results.
The proof for that is the rejection of some projects by the EB that DOEs had regarded as additional. We hope that the VVM will close the gap in interpretation not only by the document itself, but also through the process that leads to it.
This story was first published in Point Carbon News.
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