Requirements for validation
In order to be validated, the project activity must meet the validation requirements set out in 3/CMP.1, Annex, paragraph 37. In brief, the requirements for validation by a designated operational entity (DOE) are that:
- The participation requirements (set out in 3/CMP.1, Annex, paragraph 28-30) have been met. Those requirements are that:
- The comments of local stakeholders have been received and taken into account;
- The likely environmental impacts of the project activity have been assessed;
- The project will result in greenhouse gas reductions that are additional; and
- The baseline, monitoring, verification and reporting proposals (and all other aspects of the project) comply with the CDM requirements.
The requirements for validation are set out in full below:
The designated operational entity selected by project participants to validate a project activity, being under a contractual arrangement with them, shall review the project design document and any supporting documentation to confirm that the following requirements have been met:
- The participation requirements as set out in paragraphs 28-30 above are satisfied
- Comments by local stakeholders have been invited, a summary of the comments received has been provided, and a report to the designated operational entity on how due account was taken of any comments has been received
- Project participants have submitted to the designated operational entity documentation on the analysis of the environmental impacts of the project activity, including transboundary impacts and, if those impacts are considered significant by the project participants or the host Party, have undertaken an environmental impact assessment in accordance with procedures as required by the host Party
- The project activity is expected to result in a reduction in anthropogenic emissions by sources of greenhouse gases that are additional to any that would occur in the absence of the proposed project activity, in accordance with paragraphs 43-52 below
- The baseline and monitoring methodologies comply with requirements pertaining to:
- Methodologies previously approved by the Executive Board; or
- Modalities and procedures for establishing a new methodology, as set out in paragraph 38 below
- Provisions for monitoring, verification and reporting are in accordance with decision 17/CP.7, the present annex and relevant decisions of the COP/MOP
- The project activity conforms to all other requirements for CDM project activities in decision 17/CP.7, the present annex and relevant decisions by the COP/MOP and the Executive Board (3/CMP.1, Annex, paragraph 37; previously 17/CP.7, Annex, paragraph 37).
The additionality requirement
The Executive Board provided further clarification EB 11, Annex 6 on the additionality requirement in paragraph 37(d), stating that the DOE must provide a statement of the likelihood that the project will result in additional emission reductions:
In issuing a validation opinion in the validation report regarding paragraph 37 (d) of the CDM modalities and procedures the DOE shall include a statement of the likelihood of the project activity to achieve the anticipated emission reductions stated in the CDM-PDD. This statement will constitute the basis for the calculation of the registration fee (EB 11, Annex 6).
Process for inviting stakeholder comments
The Executive Board has clarified that the stakeholder consultation process described in paragraph (c) above must be conducted in an open and transparent manner, allowing a reasonable time for comment and describing project activities in an easily comprehensible way:
An invitation for comments by local stakeholders shall be made in an open and transparent manner, in a way that facilities comments to be received from local stakeholders and allows for a reasonable time for comments to be submitted. In this regard, project participants shall describe a project activity in a manner which allows the local stakeholders to understand the project activity, taking into account confidentiality provisions of the CDM modalities and procedures (EB 8 Annex 3, paragraph 2(b)).
Note: Whilst EB 54, Annex 28 has replaced EB 8, Annex 3, the previous procedures remain informative and may provide guidance where the new procedures are otherwise silent.
Requirements for new or revised baseline and monitoring methodologies
Certain additional requirements apply where the DOE determines that the project intends to use a new or revised baseline and monitoring methodology. Before undertaking validation, the DOE must forward the proposed methodology together with the draft PDD to the Executive Board for review. The Executive Board will review the proposed new methodology within 4 months. Once it has been approved, the Executive Board will make the new methodology publicly available and the DOE can proceed with validation.
This is set out in full in 3/CMP.1, Annex, paragraph 38:
If the designated operational entity determines that the project activity intends to use a new baseline or monitoring methodology, as referred to in paragraph 37(e)(ii) above, it shall, prior to a submission for registration of this project activity, forward the proposed methodology, together with the draft project design document, including a description of the project and identification of the project participants, to the Executive Board for review. The Executive Board shall expeditiously, if possible at its next meeting but not later than four months, review the proposed new methodology in accordance with the modalities and procedures of the present annex. Once approved by the Executive Board it shall make the approved methodology publicly available along with any relevant guidance and the designated operational entity may proceed with the validation of the project activity and submit the project design document for registration. In the event that the COP/MOP requests the revision of an approved methodology, no CDM project activity may use this methodology. The project participants shall revise the methodology, as appropriate, taking into consideration any guidance received (3/CMP.1, Annex paragraph 38, previously 17/CP.7, Annex, paragraph 38; EB 7, paragraph 8).
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