Post Registration Changes How to Address? Sustainable Development Mechanisms, UNFCCC secretariat
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1 Post Registration Changes How to Address? Sustainable Development Mechanisms, UNFCCC secretariat
2 Procedures available for Post registration changes Four (4) procedures have been developed to facilitate the resolution of these issues: a) Procedures for Requests for Deviation Prior to Submitting Request for Issuance - EB49 Annex 26 b) Procedures for Revising Monitoring Plans in accordance with Paragraph 57 of the Modalities and Procedures for the CDM - EB49 Annex 28 c) Procedures for Notifying and Requesting Approval of Changes from the Project Activity as Described in the Registered Project Design Document - EB48 Annex 66, 67 d) Changes to the start of the crediting period.
3 Request for Deviation If the monitoring has not been conducted in accordance with the registered monitoring plan for the verification period under consideration. The deviation shall be project specific and once approved by the CDM Executive Board the deviation applies only to the monitoring period under verification. The DOE shall provide assessment of the deviation, including description of the impact of the deviation on the emission reductions.
4 Request for Revision of Monitoring Plan If the monitoring plan is not in accordance with the monitoring methodology applied to the registered CDM project activity and/or does not reflect the actual monitoring activity based on the registered PDD. The proposed revision of the monitoring plan: a) ensures that the level of accuracy and completeness in the monitoring and verification process is not reduced b) is in accordance with the approved monitoring methodology, and c) the findings of previous verification reports, if any, have been taken into account.
5 Notification or Approval of Changes from the PDD If a post registration change raises concerns regarding: a) Additionality of the project activity, b) Applicability/application of methodology, and c) Scale of project activity
6 Post Registration Changes to the start of the crediting period The procedure has been revised and the earlier requirement for the host country DNA to re-confirm that the delay shall not impact the sustainability of the project (Annex 59, EB52). The start date can be moved upto one year earlier than mentioned in the PDD (provided the revised date is after the registration of the project) The start date can be delayed upto one year. The start date can be delayed more than one year (2 yrs for LDCs) but less than two year (4 yrs for LDCs), if DOE validates the conservatives of the baseline.
7 Deviation Vs Request for Revision of Monitoring Plan A deviation is relevant only to the monitoring period under verification, whereas a revision of monitoring plan is relevant if the changes are applicable to the entire crediting period.
8 Revision of Monitoring Plan Vs Changes from PDD Revision of monitoring plan is relevant if the changes are in the monitoring section of the PDD, whereas the notification or approval of changes is relevant if physical and permanent changes in the project affects other sections of the PDD. Where there are changes to the monitoring of a project activity that have resulted from physical or operational changes to the project activity these can be included in the submitted notification or request for approval of Changes to PDD.
9 Example 1: Description: The monitoring plan of a Hydro power project specify accuracy class of main meter as 0.2S. Situation: In the first monitoring period due to non availability of meter with 0.2S accuracy, another meter of accuracy 0.5S was used for monitoring which was replaced later in the second monitoring period with meter of 0.2S accuracy. Solution: Request for deviation since the situation is specific to the monitoring period.
10 Example 2: Description: The monitoring plan of a Hydro power project specify accuracy class of main meter as 0.2S. Situation: Due to non availability of meter with 0.2S accuracy, another meter of accuracy 0.5S was installed for monitoring. Solution: Request for revision of monitoring plan since changes will remain for the entire crediting period.
11 Example 3: Description: The PDD of a biomass residue based power plant supplying electricity generated to the grid mentions use of briquettes as fuel. Situation: Due to non availability or some technical problems wood chips are used instead of briquettes. Solution: Request for notification or approval of changes from the PDD.
12 Example 4: Description: A 15 MW biomass residue based power plant supplying electricity generated to the grid use bagasse as fuel. Situation: A 16 MW plant was installed and in additional to bagasse other biomass like cotton straw, wood chips will be used. Solution: Include both changes in the scale of project and monitoring parameters so both the Revision of monitoring plan and changes from PDD procedures are relevant. Only changes of PDD is sufficient as per EB 59.
13 Up-coming changes to the current procedures! Merge, by means of clear requirements in the relevant standards and procedures into the issuance process: " Revisions to the monitoring plan and requests for deviations for which a clear standard has been established; " The Notifications category from the Procedures for Notifying and Requesting Approval of Changes from the Project Activity as described in the Registered Project Design Document.
14 Up-coming changes to the current procedures! Limit prior approval by EB on requests for changes in the registered PDD to cases where: " Changes from the project activity that may adversely affect additionality of the project activity; application and/or applicability of monitoring methodology; or scale of project activity; " Proposed changes from the project activity that have not yet been implemented; " Revisions to the monitoring plan (including temporary and permanent deviations from the monitoring methodology) that cannot be addressed directly in the issuance; " Changes in the start date of the crediting period; " Corrections to the registered PDD (i.e. factors or parameters established at validation).
15 Questions Discussion
16 Thank You! Please visit our websites for more information CDM UNFCCC website cdm.unfccc.int CDM Bazaar Catalogue of decisions:
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