Summary of Public call for Inputs on PoA Presentation title Workshop on Programme of Activities under the Clean Development Mechanism: Challenges and the Road Ahead Summary of Public call for Inputs on PoA Bonn, 7- 8 May 2011 AMIT THUSU UNFCCC Secretariat SDM programme

CDM - Programme of Activities Background- Work on PoAs Call for public inputs on Programme of Activities (PoA) Executive Board, at its 59th meeting, agreed to launch a call for public inputs on programme of activities (PoA) from 18 February 2011 until 18 March 2011, to seek comments on issues associated with the development and scaling-up of PoAs and barriers faced. In addition to expressing views regarding the implementation of paragraph 4 of decision 3/CMP.6, the Board specially seeks for inputs, in the above context, on the following: (a) What are the possible alternative concepts for a PoA? (b) What are the barriers in the current rules? (c) What are the rules that are not existing or are missing and should be there? A total of 19 inputs were received publicly available on www.unfccc.int Summary of the call for inputs: Annex 7 of the annotations to the agenda/ EB60. 2

CDM - Programme of Activities Call for Inputs : Total of 19 inputs received Overview of the Submitters List of Organisations/submitters of Public Inputs on PoA (18 February -18 March 2011) S.No. Name of the Submitter Organisation Intrested in Attending Workshop 1 Baroda Indonesia   2 Sumit Barat 3 Foo Siew Theng Gen Power 4 Ambachew F. Admassie 5 Lara Olsen Cool nrg Carbon Investments Pty Ltd Yes 6 Ms. Chisako URAYAMA IInstitute for Global Environmental Strategies (IGES) 7 Vikas Menghwani Emergent Ventures India pvt. Ltd. 8 Jiwan Acharya Asian Development Bank 9 Mysore Raghavendra 10 - DNA of Spain 11 Rajesh R. Madiwale Thermax Sustainable Energy Solutions Ltd 12 Werner Betzenbichler DoE/AIE Forum 13 Gareth Phillips Project Developers Forum 14 Henry Derwent/Kim Carnahan IETA 15 Adriaan Tas Carbon Africa Limited 16 Klaus Oppermann World Bank 17 Ole Meier-Hahn Bridge Builders UG 18 Naoki Experts Ltd. Climate Experts Ltd./ PEAR Carbon Offset Initiative Ltd. 19 Mr. Rainer Winter/ Jun Wang TUV Nord

CDM - Programme of Activities Overview of Main Comments/Issues raised Comments are rather critical, with most commentators showing willingness to scale-up the existing concept rather than develop a new alternative concept. Most of the comments are related to the issues on additionality, DoE liability, eligibility criteria for CPA Inclusion, DNA and LoA, approval for application of multiple methodologies. Some of the comments are related to the issues on requirement of new rules and procedures on PoA such as extension of micro scale additionality to PoAs, sampling guidance, post registration changes to PoAs Other comments are related to the issues on frequency of issuance requests, allowing same DOEs work on CPA inclusion as well as verification and registration fee calculation for multi-country PoAs (e.g. LDCs) Other comments are related to the infrastructure and management issues on lack of IT processes and single dedicated contact person for PoAs. Some comments are related to lack of capacity development on PoAs particularly to CMEs and CPA implementers Some comments are on extension of PoA framework to NAMAs 4

CDM - Programme of Activities COMPARISON: 2011 Vs 2008 5

CDM - Programme of Activities Feedback and Prioritize POA Issues What are the barriers in the current rules? (1)

CDM - Programme of Activities What are the barriers in the current rules? (1) Additionality Allow Investment analysis and small scale additionality guidelines to be applicable to PoAs Clarity on Additionality for Policy based PoAs

CDM - Programme of Activities Feedback and Prioritize POA Issues What are the barriers in the current rules? (2) 8

CDM - Programme of Activities What are the barriers in the current rules? (2) Application of methodologies to PoAs Approval for Application of Multiple Methodologies is discouraging due to additional delay and process of application needs to be detailed Multiple versions of PoAs due to revision of methodologies is a barrier Application of Multiple Technologies/Baselines Suggestions: Use of default/ standardized emission factors, such as electricity grid emission factor would contribute to improve the opportunities for PoAs, particularly in LDCs.

CDM - Programme of Activities Feedback and Prioritize POA Issues What are the barriers in the current rules? (3) 10

CDM - Programme of Activities What are the barriers in the current rules? (3) CPA inclusion to PoA Currently CPA inclusion form to be filled-in by the DOE during CPA validation indicates checking almost all the major CDM parameters/issues (e.g. consistency/integrity, internal quality control aspects, additionality, emission factors). The lack of guidance for CPA inclusion into the PoA results in an overly cautious approach by the DOEs Suggestions: - Provide guidelines for the defining the eligibility criteria, including also a sub-section in the PoA-DD on how the DOE is to judge whether the criteria are met.

CDM - Programme of Activities Feedback and Prioritize POA Issues What are the barriers in the current rules? (4) 12

CDM - Programme of Activities What are the barriers in the current rules? (4) Designated Operational Entity Liability Perception that currently the liability is open ended and infinite and can be triggered at any point during lifetime of PoA and this creates unmanageable risk. High transaction costs are due to full liability and full checking Gross negligence is by no way applicable to situations where individual CPAs have not been scrutinized in verification activities according to a documented sampling plan Suggestions: - Introduce time limit to liability, option of sharing liability, liability be limited to fraud/gross willful misconduct by DoE & CMEs and limit the scope of reviewing included CPAs

CDM - Programme of Activities Feedback and Prioritize POA Issues What are the barriers in the current rules? (5) 14

CDM - Programme of Activities What are the barriers in the current rules?(5) DNA and LoA Issues DNA face difficulties in evaluating sustainable development as LoA is not required for CPA inclusion – require sampling approach here as well Consequences of post registration LoA withdrawal or revocation for one or multi-country PoA Some LoA that requires to mention emission reduction ex-ante

CDM - Programme of Activities Feedback and Prioritize POA Issues What are the rules that are not existing or are missing and should be there? 16

CDM - Programme of Activities What are the rules that are not existing or are missing and should be there? New rules/procedures for PoA Template for Monitoring Report for a PoA Guidance on Materiality Applicability of the existing rules to programme of activities Explicitly state which existing CDM rules apply to PoAs. Revision of documentation due to inconsistency between PoA-DD and CPA-DD Revision of VVM to make it more applicable to PoAs and maintain consistency Other Issues Clarity on the registration fee calculation in the case of multi-country PoA that includes both LDCs and non-LDCs. Allow DoEs performing CPA inclusion to carryout verification

CDM - Programme of Activities Executive Boards Decision – EB60 Work on Programme of Activities (PoA) Clarifications provided (EB60/ Annex 26) Priorities was decided by the Board (EB60/ Annex 27) 18