. Aim of this session To calibrate the understanding of the new requirements under the new package of documents, i.e. – post registration changes and other cross-cutting issues; – to discuss the role of each stakeholder during their implementation PP DOE RIT member secretariat
. DOE perspective As the project cycle procedure will only come into effect on 1 May 2012, DOEs are going through the process of developing new processes and templates and have as yet little experience of practical implementation. The comments that follow are based on experiences of interpreting the texts of the new procedures and standards.
. We welcome many aspects of the new framework In particular – The revised monitoring report form and guidance help demonstrate accountability on Project Participants declaration of correct information/status of project activity – The opportunity to have a conference call regarding issues raised during the secretariats review of documents. – The possibility to have post registration changes which do not require prior approval by the EB. – The possibility to correct minor editorial errors without the project being returned to the queue
. We have found some lack of clarity during implementation eg: Project Standard Appendix 1: (Changes that do not require prior approval by the board) – we ask that the list of changes presented in Appendix 1 of the CDM Project Standard will be further developed over time. – eg: any corrections to project information……that do not affect the design of the project activity in appendix I of Project Standard. There is a footnote saying that such corrections may include typographical errors, location, names and numbers of components, etc. whilst Changes to the project design of a registered project activity are elsewhere defined to include addition of component. Minor editorial errors, – it would be useful to have guidance on what constitutes editorial errors. This is to ensure equal treatment of all projects by different members of the UNFCCC Secretariat.
. We have found some lack of clarity during implementation (cont) Definitions of changes – 267. Where permanent changes are identified during verification, the DOE shall indicate in the verification report how the revised PDD reflects the application of the approved guidance from the Board regarding the permanent changes from the provisions of the registered monitoring plan and/or methodology. – 268. Where permanent changes are identified prior to verification, the DOE shall state its opinion on whether the permanent changes reflect the application of the approved guidance from the Board regarding the deviation from the provisions of the registered monitoring plan and/or methodology. – Is the EB31 clarification on definitions of revision and deviation applicable under the new standards? Submission and treatment of public comments (Para 20, PCP): – Sometimes stakeholders comments are not related to the PA/erroneous comments/defamatory for DOE or CDM Mechanism – the procedure to deal with such cases is not clear
. Recommendation We ask that the secretariat is available to clarify uncertainties raised by DOEs during implementation of the new procedures to avoid unnecessary problems for projects during the 2012 busy period. We recommend – establishing a new standards focal point within the secretariat to which questions from PPs or DOEs can be directed by email/telephone – publishing frequently asked questions and guidance available to PPs and DOEs – committing to an update of documents later in the year with the benefit of lessons learned during implementation