Revising and withdrawing an approved methodology
In certain circumstances, the revision of an approved methodology may be required. A revision in this context is defined as:
...the modification of an approved methodology in order to improve it or broaden its scope and applicability. The revision results in the approved methodology with a new version number (EB 27 Annex 10, paragraph 3).
However, there is conflicting guidance on this point - some decisions suggest that any modification will result in a new ‘version' of the same methodology, while others suggest that only minor corrections can result in a new ‘version' and major corrections will result in an entirely new methodology:
For minor revisions and corrections a simplified procedure is foreseen: They are to be approved as "versions" rather than "revisions" as is the practice of the Board. Minor revisions include also the incorporation of a proposed new methodology into an approved methodology that requires only minor modification. The source and project participant of the incorporated methodology should be mentioned in the new version. Minor revisions (including incorporations) result in a new "version" of the approved methodology, rather than a new consolidated methodology (EB 27 Annex 10, paragraph 6).
Revisions of methodologies must be carried out in accordance with the modalities and procedures for establishing new methodologies.
Effect of revisions and withdrawals on registered project activities
Revisions and withdrawals of approved methodologies do not affect:
- Project activities that, at the time of the revision or withdrawal, have already been registered using the old methodology; or
- Project activities that, at the time of the revision or withdrawal, have already been published for public comments (as part of the validation process) using the old methodology, but only if the project is then submitted for registration within 8 months of the date of the revision or withdrawal.
This rule was first set out in 3/CMP.1, Annex, paragraph 39:
A revision of a methodology shall be carried out in accordance with the modalities and procedures for establishing new methodologies as set out in paragraph 38 above. Any revision to an approved methodology shall only be applicable to project activities registered subsequent to the date of revision and shall not affect existing registered project activities during their crediting periods (3/CMP.1, Annex, paragraph 39).
Clarification on this decision was provided by the Executive Board at EB 54, Annex 2, paragraph 35:
35. The amendment of an AM [approved baseline and monitoring methodology] or an AT [approved tool] has no effect on the global stakeholder consultations of PDDs and registration of project activities applying the previous version of the amended AM or AT.
Where a project activity, which has been published for public comments for validation using an old methodology, is submitted for registration within 8 months of the effective date of the revision of that methodology, that project can continue to use the old methodology. The Executive Board clarified at EB 54 that a project will be considered to meet this deadline if the following conditions are satisfied:
a. The DOE has uploaded the request for registration using the dedicated interface of the UNFCCC CDM website before 24:00 GMT on the day of the deadline; [and]
b. Either the proof of payment is uploaded within 20 calendar days after the deadline or the payment is received within 40 calendar days after the deadline (EB 54, Annex 2, footnote 5).
Fulfilment of these conditions is verified by an automated process.
When can revisions be carried out?
The circumstances when revisions of approved methodologies can be carried out are set out in Clarifications to project participants on when to request a revision, clarification to an approved methodology or a deviation (EB 31, Annex 12; previously EB 30, Annex 1), and also in the Criteria for consolidations and revision of methodologies (EB 27 Annex 10).
A revision may be carried out when:
- new or a better understanding of scientific evidence indicate that emission reductions may be over- or under estimated based on the existing approved methodology or that the reductions may not be real, measurable and verifiable;
- the applicability conditions require broadening to include more potential project types or conditions for use;
- there are identified inconsistencies, errors and/or ambiguities in the language and/or formulae used within or between methodologies;
- there is scope for simplification and or more clarification in order to improve its user-friendliness (also to include clarifications that have been given by the Meth Panel in response to queries regarding the applicability of approved methodologies) (EB 27 Annex 10, paragraph 4).
The revision of approved methodology may be carried out in response to requests by a project participant, relevant stakeholders, the Executive Board, the Meth Panel or Working Groups in accordance with the latest version of the procedures (EB 31 Annex 12, paragraph 5).
The revision may be carried out in response to requests recommended in the meetings by the COP/MOP, Executive Board, the Meth Panel and working groups. In addition revisions may be carried out in response to request for revisions as per the procedures for revisions (EB 27 Annex 10, paragraph 5).
It is appropriate for a project participant to request a revision when the proposed project activity is broadly similar to the project activity to which an approved methodology applies:
A request for revision is suited for situations where an approved methodology is not applicable to a project activity but the project activity is broadly similar to the project activities to which the approved methodology is applicable. Similarity is based on the nature (technology/measure) of the project activity and sources of the emissions affected by the project activity.
For example, the approved methodology may not be applicable as the source of emissions affected by the project activities are the same but the technology/measure used in the project activity is not covered under the applicability conditions; or the procedures provided in the methodology for estimating emissions from sources are not applicable because of slight variations in the approach, flow of events or structure chosen in the project activity (EB 31 Annex 12, paragraph 6).
However, if no approved methodology is appropriate for revision, then methodologies may be consolidated. The full text of the decision referring to this rule is reproduced below; however, pending clarification from the UNFCCC Secretariat, it is assumed that the word 'revision' should be replaced with the word 'consolidation', as indicated:
Should no approved methodology be appropriate, then a revision [replace with 'consolidation'?] to an approved methodologies could be requested. In this case significant changes are required to the approved methodology for it to be applicable to all possible project scenarios, without which inter alia the application of the methodology to the proposed project activity would be inappropriate, resulting in an incorrect definition of the project boundary, double counting, an inaccurate account of leakage, emission reductions that are either not real, measurable, verifiable or additional to those that would occur in the absence of the project activity (EB 31 Annex 12, paragraph 7).
A new proposed methodology will be required where the request for revision limits the ability of other projects activities to use the applicability conditions of approved methodologies:
The request for revisions shall not include changes to the approved methodology that would result in the exclusion, restriction, narrowing of the applicability conditions of the approved methodologies for other project activities. Should the request result in the above the project participant is advised to submit a new proposed methodology (EB 31, Annex 12, paragraph 8).
Project participants are discouraged from requesting revisions to more than half of the sections of an approved methodology:
In this regard, if the request for revision to an approved methodology is likely to result in the addition of new procedures or scenarios to more than half of the sections of an approved methodology, it is advisable that project participants propose a new methodology as per procedures for submission and consideration of proposed new methodology accordance with the latest version of the procedures (EB 31 Annex 12, paragraph 9).
A revision of an approved methodology need not follow a request by Project Participants. The Meth Panel may also initiate a revision:
7. The Meth Panel and/or the secretariat may initiate the revision of an AM or an AT in order to simplify it and/or improve its objectivity, applicability, usability and consistency (EB 54, Annex 2, paragraph 7).
In addition, the secretariat or the EB may also request the revision of an AM or an AT.
Project participants who wish to propose a revision to an approved methodology must submit the required documents to a DOE:
Project participants submit a request for revision of an AM or an AT by submitting the following documents to a DOE:
a. A draft of the proposed revised AM or AT highlighting all proposed changes; and
b. A project design document form for a CDM project (form CDM-PDD) with at least section "Application of an approved baseline and monitoring methodology" (including relevant annexes) completed as a draft, providing an example of the application of the revised AM or AT. (EB 54, Annex 2, paragraph 8).
The DOE will check the documentation and submit a request for revision via the interface provided on the UNFCCC CDM website:
The DOE then:
a. checks the completeness of the documents received from project participants;
b. completes a form for submission of requests for revision of approved methodologies to the Meth Panel (form F-CDM-AM-Rev); and
c. submits them using the submission interface for requests for revision on the UNFCCC CDM website. (EB 54, Annex 2, paragraph 9).
Where a request for a revision of an AM or an AT is technically complex, and with the approval of the Chair of the Meth Panel, the secretariat may request an assessment by one or two consultants, whereupon:
Each consultant performs an independent assessment of the request for the revision and reports the outcome to the secretariat (EB 54, Annex 2, paragraph 15).
Depending on its assessment of the technical complexity of the draft revision, and with the approval of the Chair of the Meth Panel, the secretariat is to make the draft revision public available for comment:
a. makes the draft revised AM or AT publicly available on the UNFCCC CDM website and invites public comments for a period of 10 calendar days;
b. informs the public of the call for public comments through the CDM newsletter;
c. at the end of the period, makes all public comments publicly available on the UNFCCC CDM website; and
d. accommodates relevant public comments into the draft revision. (EB 54, Annex 2, paragraph 21)
The secretariat will also prepare a draft recommendation to be considered by the Meth Panel:
a. prepares a draft recommendation on the request for revision taking into account the report(s) of the consultant(s) (if any); and
b. selects one or two members of the Meth Panel to: (i) assess the request for revision, taking into account the secretariat's draft recommendation; (ii) considers whether the improvements applied in the AM or the AT increase conservativeness over the previous version; and (iii) prepares an initial recommendation for consideration by the Meth Panel. (EB 54, Annex 2, paragraph 16).
The Meth Panel then considers the request:
The Meth Panel:
a. considers the request for the revision and the initial recommendation prepared by the member(s), including the statement that the revision leads to an increase in conservativeness over the previous version, if any; and
b. finalises its recommendation over the course of no more than two meetings unless additional guidance from the Board or the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol (CMP) is required (EB 54, Annex 2, paragraphs 17).
In circumstances where the request is submitted by project participants and the initial recommendation by the secretariat indicates a high probability that the Meth Panel will recommend the Board to approve the revision, the secretariat is to send the draft revision to the project participants at least two weeks before the Meth Panel meeting at which the draft revision is included on the meeting agenda for consideration (EB 54, Annex 2, paragraph 18). In these cases, the project participants may do the following:
a. inform the secretariat that the draft revised AM or AT is applicable to their project; or
b. identify changes that are needed in the draft revised AM or AT in order to make it applicable to their project and request the Meth Panel to consider them.
If such changes are requested, the Meth Panel is to consider these and attempt to accommodate them into the draft revised AM or AT. If the Meth Panel cannot accommodate the project participants' requests, it may recommend the draft revised AM or AT to the Board without accounting for the project participants' requests, explaining why the project participants' requests could not be accommodated (EB 54, Annex 2, paragraph 20).
At each Meth Panel meeting where the request for the revision is considered, the Meth Panel must:
a. report its final recommendation to the Board to approve the revision (including a statement that the revision leads to an increase in conservativeness over the previous version, if there exists a previous version); or
b. report its final recommendation to the Board not to approve the request for the revision; or
c. continues its consideration of the request for the revision (which is referred to as a WIP or work in progress), though during a time period not exceeding two meetings. (EB 54, Annex 2, paragraph 22).
Where the Meth Panel agrees to recommend the draft revised AM or AT to the Board, the secretariat then places the consideration of the recommendation on the request for revision on the annotated agenda of the subsequent EB meeting (EB 54, Annex 2, paragraph 23).
Where the Meth Panel cannot agree upon a final recommendation to the Board, then the reason is briefly explained in the meeting report of the Meth Panel and the consideration of the request for the revision is continued (referred to as a WIP) (EB 54, Annex 2, paragraph 24).
The EB then considers the revised AM or AT. Where the EB agrees to approve the revised AM or AT, the approved revised version is published on the UNFCCC CDM website. The secretariat is responsible for ensuring that all approved revised AMs and ATs are made available in the approved methodologies section of the UNFCCC CDM website within 5 calendar days from the publication date of the report of the EB meeting at which the AM/AT is approved.
If the EB agrees not to approve the revised AM or AT, project participants may resubmit a request for revision at any time following this revision procedure.
Methodologies put ‘on hold' during the revision process
Where a significant revision is required, it may be necessary to put the use of a methodology ‘on hold’: Should an approved methodology require a significant revision, its further use shall be put on hold and its revision be undertaken in an expedited manner (EB 27 Annex 10, paragraph 7). The Procedure for the Submission and Consideration of Requests for Revision of Approved Baseline and Monitoring Methodologies and Tools for Large Scale CDM Project Activities (EB 54, Annex 2) currently governs the revision of methodologies. Nonetheless, EB 35, Annex 13 (which EB 54, Annex 2 replaces) contains helpful guidance in relation to methodologies put 'on hold':
If the Board considers that the possible revision of the methodology could have significant implications for the use of the methodology, the Board may agree to suspend the use of the methodology, by putting it “on hold”, with immediate effect (EB 35, Annex 13, paragraph 18).
Project activities that are registered or have been submitted for registration within 4 weeks of the methodology being put ‘on hold’ will not be affected. Other projects, however, will not be permitted to use the methodology until a decision on the revision has been made:
Project activities using such a methodology that have not been submitted for registration within four (4) weeks after the methodology has been put “on hold”, will not be permitted to use the methodology until the Board has made a decision with respect to the methodology. (EB 35, Annex 13, Section II(19)).
However, if a methodology is put ‘on hold’, a revised methodology must be made available within 3 Executive Board meetings:
If the Board puts a methodology “on hold”, in accordance with paragraph 16 above, a revised methodology should be approved no later than the third Board meeting after the methodology has been put “on hold”. (EB 35, Annex 13, Section II(20)).
In addition to the above, if a revision is requested by the COP/MOP:
a. no CDM project activity may use the methodology requested to be revised; and
b. the panel/working group shall revise the methodology, as appropriate, taking into consideration any guidance received (EB 35, Annex 13, paragraph 3).
Version 1 of the Procedure for the Submission and Consideration of Requests for Revision of Approved Baseline and Monitoring Methodologies and Tools for Large Scale CDM Project Activities (EB 54, Annex 2) replaces version 9 of the Procedures for the Revision of an Approved Baseline or Monitoring Methodology by the Executive Board (EB 35, Annex 13) and all previous versions, including EB 32 Annex 14 (Ver 8), EB 31 Annex 13, EB 28 Annex 16, EB 25 Annex 18, EB 23 Annex 3, EB 21 Annex 6, EB 19 Annex 3.
As such, it is not clear as to whether the guidance in EB 35, Annex 13 (as it applies to methodologies put 'on hold') is currently being applied.