1. 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

2. 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
Summary of the call for inputs: Annex 7 of the annotations to the agenda/ EB60. 2

3. 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

4. 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

5. CDM - Programme of Activities
COMPARISON: 2011 Vs 2008 5

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

7. 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

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

9. 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.

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

11. 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.

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

13. 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

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

15. 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

16. 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

17. 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

18. 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