Revision of PoA-related regulatory documents

Transcription

1 Paragraph 26 of the annotated agenda, Annex 6 Revision of PoA-related regulatory documents CDM EB 80 Bonn, Germany, 14 July to 18 July 2014 UNFCCC Secretariat SDM programme

2 Background and purpose EB 78 agreed on further work on PoA standards for simplification (Table 1, annex 8, EB 78) EB78 also requested to assess whether further guidance would be required in section of the PCP, Requesting review of request for issuance with regard to multicountry PoAs. 2

3 Background and purpose The following issues are covered: Issue 1: Post-registration changes to PoA; Issue 2: Definition of types of generic CPA-DDs; Issue 3: Multiple specific CPA-DDs per generic CPA-DD at registration of PoA; Issue 4: Requesting review of request for issuance for multi-country PoAs; Issue 5: Requirements to estimate multiple parameters in a single survey; Issue 6: Sample size calculator; Other editorial revisions. 3

4 Issue 1: Post-registration changes to PoA UNFCCC Secretariat SDM programme

5 Procedural background Currently eligible post-registration changes (PRC) to registered PoAs are limited (as compared to regular projects). For example: a) Technologies/methodologies applied in the PoA remain fixed; b) Changes to eligibility criteria by CME in the PoA-DD are restricted. Stakeholders request clarity/simplification( e.g. 19th DOE teleconference, RCC workshops and other submissions) 5

6 PRCs to add/change technology/measure Types of changes Modification/addition of technologies Conditions for changes Modified/added technologies comply with applicability conditions of applied methodologies Modified/added technologies and eligibility criteria were already included in the registered PoA-DD Modified/added technologies and eligibility criteria included in the revised PoA- DD following a request for clarification and approval of PRC by the Board C u r r e n t P r o p o s e d 6

7 PRCs to change eligibility criteria by the CME Types of changes Conditions for changes Changes to programme boundary Updates to the eligibility criteria Addition of specific CPA-DDs Removal of methodologies Version of meth applied is revised or replaced after being put on hold To reflect changes due to amendment of programme boundary Initiated by the Board due to issue on environment integrity At the PoA crediting period renewal To adopt the latest versions of standards, guidelines and methodologies P r o p o s e d C u r r e n t 7

8 Typical changes to technology/measure a) Changes to shift to more efficient or equivalent technologies for similar applications Ex. Design change Meth change 1 From CFL to LED lighting Add new methodologye.g., AMS-III.AR 2 From CFL lamps in Solar Home System to LED lamps with the same SHS 3 From improved cookstoves using nonrenewable biomass to renewable energy cookstoves 4 Introducing institutional cookstoves to a registered household cookstoves PoA 5 Introducing charcoal-burning stoves to a registered PoA distributing household wood-burning stoves Same methodology used (e.g. AMS-II.C, AMS- III.AR) Change/addition of methodology AMS-I.E from/to AMS-II.G Same methodology is applied (AMS-II.G) Same methodology is applied (AMS-II.G) 8

9 Typical changes to technologies/measures b) Changes that introduce compatible measures/technologies: Ex. Design change Meth change 6 From flaring to utilization of recovered methane to generate heat or electricity Add Type I methodology to a PoA applying a Type III waste/wastewater methodology c) Moving to a more suitable methodology that has recently become available Ex. Design change Meth change 7 Switching from a generic to a more project-specific methodology From AMS-I.C to AMS-I.I for thermal energy from biogas 9

10 Typical revisions of eligibility criteria in the registered PoA-DD a) Change from conventional methods of demonstrating additionality Ex. Change in eligibility criteria 8 Shift from barriers/additionality tool to positive lists under smallscale or micro-scale additionality guidelines b) Changing the means to demonstrate compliance with requirements on avoidance of double counting Ex. Change in eligibility criteria 9 Using manufacturers serial number stamped on the equipment instead of marking equipment with project logo 10

11 Recommendations to the Board The secretariat recommends: To allow CMEs to seek prior-approval by the Board of proposed PRC through a clarification request; To mandate the SSC WG to develop top down a list of allowable changes for recommendation to the Board; If the proposed PRC are approved, the CME shall revise all specific-case CPA-DDs to align with the revised version of the PoA- DD. 11

12 Stakeholder Inputs to the EB80 Annotated Agenda (World Bank) Post-registration changes to PoA: Support the recommendation to: Expand post registration changes to include the addition/change of related technologies/measures and methodologies that allow for shifting to more efficient or equivalent ones without compromising the ER estimates (Para 15). Permit the changing of PoA eligibility criteria to account for any improvements in methodologies and/or, additionality demonstration, if CME wishes to apply the relevant revised version of a methodology or tool (Para 19). Suggest that regulations allow developers flexibility to access better alternative technologies/measures occurring as a result of changing policy/economic conditions during a crediting period. E.g. to permit a household to change from use of stand alone systems (SHS) to the grid or mini-grid connection. Clear guidance on the information needed for re-assessment of baseline and probably additionality would be useful for many rural electrification programs. 12

13 Issue 2: Definition of types of generic CPA- DDs UNFCCC Secretariat SDM programme

14 Procedural background Stakeholders requested clarity on definition of different types of generic CPA-DDs for PoAs; Definition impacts PoA documents (e.g. number of generic CPA- DDs, specific CPA-DDs). Raised by DOE/AIE Coordination Forum (28 Oct 2013) and 20th DOE telecon in 22 October

15 Key issues and proposed solutions The CDM Project Standard (PS) states that a) For PoAs applying more than one technology/measure or more than one methodology, the CME shall prepare a generic CPA for each technology/measure, each methodology and each combination thereof. However, separate generic CPA-DDs are not required to cover cases that do not differ in terms of emission reduction calculations. Stakeholders requested further clarity and simplification to reduce transaction costs. For example, clarity on technologies: a) Charcoal burning stove vs. wood burning stove b) Portable stove vs. in-situ stove 15

16 Key issues and proposed solutions In some large-scale methodologies (e.g., ACM14), differences in the demonstration of additionality, ER calculations and monitoring methods are considered for defining a type of CPA-DD However, small scale project (e.g, solar PV or small hydro plant) may directly benefit from positive list for additionality demonstration and using standardized methods of conservative default EF. In such instances, the added value of having multiple generic CPA- DDs per technology may be limited. 16

17 Recommendations to the Board The secretariat recommends that the Board to consider the following: Option 1: to provide methodology-specific guidance in frequentlyused methodologies (e.g., lighting) defining cases for which different generic CPA-DDs would need to be submitted; Option 2: to relax the requirements in the regulatory documents for PoAs whose technologies/measures can qualify for automatic additionality in small scale or micro scale activity: a) One generic CPA-DDs may include more than one technology/measure and the specific CPA-DD may correspond to any one of the technology/measures. specific-case CPA-DD(s) for other technologies/measures may only be reviewed by DOEs before inclusion. 17

18 Stakeholder Inputs to the EB80 Annotated Agenda (World Bank) Definition of types of generic CPA-DDs: Suggest that both proposed solutions as in para 34 are approved and applied to reduce transaction costs associated with multiple generic CPA-DDs to identify each type of CPA for each type of technology/measure, each methodology or combinations of methodologies/measures planned under the PoAs (Para 34). 18

19 Issue 3: Multiple specific CPA-DDs per generic CPA-DD at registration of PoA UNFCCC Secretariat SDM programme

20 Procedural background For PoA registration, the PS allows only one specific CPA-DD for each generic CPA-DD at the time of registration, while allowing the inclusion of additional specific CPA-DDs after the PoA-DD is registered. A proposal has been made to allow the submission of more than one specific CPA-DD for one generic CPA-DD at the time of PoA registration. EB 74 requested the secretariat to analyse the issue and present possible solutions and their implications. 20

21 Key issues and proposed solutions Proposal may reduce transaction costs of CME and add certainty; If large number of CPA-DDs are submitted at the same time secretariat may find it difficult to meet the deadlines; PoA rules were designed to rely on DOEs for "inclusion of CPA- DD; Also, a minimum number of changes in the IT workflow to accept additional CPA-DDs would be required. Secretariat recommends allowing the proposal and : (a) To limit the number of specific CPA-DDs (e.g. up to five CPA-DDs ) and to extend the time for the secretariat s assessment to certain number of days; (b) Effective date of implementation has to take into account the required IT changes 21

22 Issue 4: Requesting review of request for issuance for multi-country PoAs UNFCCC Secretariat SDM programme

23 Procedural background For multi-country PoAs, the Board requested the secretariat to assess whether further guidance would be required in section of the PCP, Requesting review of request for issuance with regard to multi-country PoAs. a Party involved in the project activity or PoA and/or any member of the Board may request a review of the request for issuance within 28 days of the date of publication of the request for issuance for the project activity or within 42 days of the date of publication of the request for issuance for the PoA, respectively. 23

24 Key issues and proposed solutions PCP states that: a) A request for review shall provide the reasons based on the PS, VVS or any other applicable CDM requirements. b) If a proposed decision is to reject the request for issuance, it shall contain an explanation of the reasons and rationale for the proposed decision; It appears that the above rule may provide sufficient guidance with regard to requests for review when PoA-level issues are identified by a Party; Whereas, further clarity on the applicability of the request for review procedures when CPA-level issues are encountered, may still be needed. 24

25 Recommendations to the Board EB 79 approved batched issuance and also requested the secretariat (EB78) to assess the feasibility of further simplification: a) e.g. whether and under what conditions issuance to more than two batches or to individual CPAs in the PoA may be feasible. In such a context, the secretariat recommends to Board to consider extending the scope of the assessment to also include the issue of request for review. a) The secretariat will make a recommendation to the Board at a future meeting after analysing all related issues. 25

26 Issue 5: Requirements to estimate multiple parameters in a single survey UNFCCC Secretariat SDM programme

27 Key issues and proposed solutions For estimating multiple parameters, sampling standard provides two options: a) the largest number for the sample size for the sampling effort with one common survey; or b) the sampling effort and survey is repeated for each of the parameters. The sample size for one parameter (e.g., stove efficiency) could be much smaller than the other parameters (e.g., retention rate); Stakeholders point out that taking the largest sample size for all parameters causes disproportionate costs; Stakeholders requested to revise the sampling standard to allow sampling of all parameters within one sample as long as the random selection of sub samples can be ensured. 27

28 Recommendations to the Board Similar option has been approved by the Board in the latest version of cookstove methodology AMS-II.G. The secretariat recommends the Board to revise the sampling standard to clarify: when more than one parameter is estimated through sampling and surveys, a random sub-sample within the common survey is allowed as long as the reliability specification (e.g. 90/10 confidence/precision for small-scale project activities and 95/10 for large-scale project activities) is achieved for each individual parameter. 28

29 Stakeholder Inputs to the EB80 Annotated Agenda Atmosfair: Endorse the proposed revision of the sampling standard to reduce monitoring efforts without reducing the robustness and quality standards of the monitoring and sampling. Urge approval of the revision of the sampling standard as included in the annotated agenda to allow simplification of the monitoring for many projects with large sustainability effects and projects located in LDCs such as cook stove projects. WB: Support the recommendation to allow smaller random samples within a larger sample provided the confidence/precision levels are achieved for each individual parameter (Para 61). Encourage the Board and its panels to continue developing simple calibration defaults for commonly used monitoring equipment (e.g. thermometers for water and scales for fuel wood) in order to avoid situations where projects are required to use high-end monitoring equipment since simple technologies have no calibration requirements. 29

30 Issue 6: Sample size calculator UNFCCC Secretariat SDM programme

31 Sample size calculator As requested by stakeholders, a sample size calculator has been developed; This will facilitate the calculation of a sample size for a mean parameter value and a proportion parameter value for simple random sampling and stratified random sampling. Agenda

32 Issue 7: Other editorial revisions UNFCCC Secretariat SDM programme

33 Changes of editorial nature Some editorial revisions (e.g. to keep consistency among PS/VVS/PCP) are also proposed in this document. Agenda 4 Paragraph 27 and 28 of the annotated agenda, Annex 11 and 12 33

34 Other inputs from stakeholders UNFCCC Secretariat SDM programme

35 Other Stakeholder Inputs to EB80 related to PoA issues Other issues not addressed in Annex 6 but included in previous submission on PoA reforms in annotated agenda to EB78 (WB) Simplified CPA inclusion for PoAs addressing micro scale activities: Recommend an optional simplified CPA inclusion procedure for PoAs addressing micro scale activities to lower transaction costs, promote efficiency and predictability. Under simplified procedures the CME would directly include the micro scale CPAs into a PoA that has been registered and validated by the DOE. The CME will only include micro scale CPAs into the validated and registered PoA provided they complied with an Board preapproved simplified eligibility template. CPA threshold limits: Applying micro scale thresholds at unit level (instead of CPA level) can substantially reduce transaction costs in providing more flexibility in grouping individual activities to CPAs. Currently micro scale thresholds are applied at level of each CPA rather than at the unit level or project activities level. This results in the current practice of artificially grouping project activities (e.g. solar lighting projects) into bundles of activities that meet the threshold. 35

36 Multiple methodologies in PoA UNFCCC Secretariat SDM programme

37 Multiple technologies/methodologies in a PoA Historically PoAs were limited to a single technology/measure ( e.g. CFLs, cookstoves, biogas, solar water heater) Owing to potential and stakeholder requests Board has progressively introduced flexibility to include multiple technologies/methodologies: a) General guidelines to SSC methodologies pre approved combinations b) For other SSC combinations account for cross effects; EB68 Guidelines for consideration of interactive measures for application of multiple CDM methodologies for PoAs For LSC combination, request clarification/revision to MP

38 Cross effects example EE measures in a building Activity 1: efficient lighting bulbs Activity 2: efficient space heating/cooling Cross effect: Activity 1 will lead to increased/reduced fuel consumption for the same level of space heating/cooling.

39 SSC Pre approved combinations Combinations in SSC General Guidelines: Type III methane generating methodologies, with Type I methane utilizing methodologies o i.e. AMS-III.H, AMS-III.D, AMS-III.F and AMS-III.G, with AMS- I.A, AMS-I.C, AMS-I.D and AMS-I.F. Any combination of SSC methodologies that has been applied in a registered project

40 General requirements The CME shall list in the PoA-DD (and the generic CPA-DD) various combinations of technologies/measures and/or approved methodologies that will be implemented. The CME shall elaborate the eligibility criteria for CPA inclusion and where applicable sampling plans for each of the combinations separately.

41 Types of combinations Case 1: Same combination of technologies under same combination of methodologies in each CPA ( e.g. AMS-III.G + AMS-I.C for heat from landfill gas) Case 2: Single methodology in each CPA but with multiple technologies (hydro under AMS-I.D, wind under AMS-I.D, biomass under AMSI.D) Case 3: A principle technology in each CPA using multiple combinations of methodologies (electricity and heat from biogas, AMS-III.D + AMS-I.C, AMS-III.D + AMS-I.D) Case 4: Combinations of technologies/methodologies varies across CPAs

42 Types of combinations Applying methodologies not directly related to each other: a) CME shall demonstrate that the implementation of the activities is integrated through the design of the programme for example: A CME initiates and coordinates different emission reduction activities as part of a city-wide effort to reduce GHG emissions, implementing policy goals adopted by the city or the government. This may include different measures, such as energy production, transport, energy efficiency and waste management; A CME initiates and coordinates the installation of renewable electricity systems which may include grid-connected and offgrid systems by providing financial incentives for the installation of these systems.