What is additionality?

In the context of a Programme of Activities (PoA), the requirement of additionality means that both the PoA itself and each CDM Programme Activity (CPA) would not have been implemented, or would not have been implemented to the same extent, without registration under the CDM.

In relation to assessing additionality for the PoA, the coordinating/managing entity must demonstrate:

that in the absence of the CDM (i) the proposed voluntary measure would not be implemented, or (ii) the mandatory policy/regulation would be systematically not enforced and that noncompliance with those requirements is widespread in the country/region, or (iii) that the PoA will lead to a greater level of enforcement of the existing mandatory policy/regulation. This shall constitute the demonstration of additionality of the PoA as a whole (EB 32, Annex 39, paragraph 2(e)).

Therefore, as with other project types, PoAs addressing mandatory laws and policies are permissible provided it can be demonstrated that the law is not widely enforced:

A PoA shall comply with all current guidance by the Board concerning the treatment of local/regional/national policies and regulations. PoAs addressing mandatory local/regional/national policies and regulations are permissible provided it is demonstrated that these policies and regulations are systematically not enforced and that noncompliance with those requirements is widespread in the country/region. If they are enforced, the effect of the PoA is to increase the enforcement beyond the mandatory level required (EB 32, Annex 38, paragraph 3).

Additionality must also be considered at the level of individual CPAs. The criteria for demonstration of additionality for each CPA must be outlined in both the Programme of Activities Design Document (CDM-POA-DD) and the in the CPA Design Document (CDM-CPA-DD). Essentially, this is aimed at ensuring that each CPA will produce credible emission reductions or abatement.

Evidence must be included within the PoA Design Document (CDM-POA-DD) to show that all CPAs will produce net greenhouse gas emissions abatement or sequestration:

The PoA shall demonstrate that net reductions in anthropogenic emissions or net anthropogenic greenhouse gas removals by sinks for each CPA under the PoA are real and measurable, are an accurate reflection of what has occurred within the project boundary, and are uniquely attributable to the PoA. The PoA shall therefore define at registration, the type of information which is to be provided for each CPA to ensure that leakage, additionality, establishment of the baseline, baseline emissions, eligibility and double counting are unambiguously defined for each CPA within the PoA (EB 32, Annex 38, paragraph 8).

For CPAs which are stationary (for example, a small hydropower plant), the guidance suggests "localisation" by providing a geographic reference. In the case of mobile CPAs it is suggested that registration numbers and GPS devices be used to keep track of their location. Tracking the location of the CPA helps to prevent the CPA being registered twice under the CDM process and also allows for monitoring and auditing of the PoA.