What is additionality?
Additionality is defined in 3/CMP.1, Annex, paragraph 43 as follows:
A CDM project activity is additional if anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the registered CDM project activity (3/CMP.1, Annex, paragraph 43).
In other words, additionality is the requirement that the greenhouse gas emissions after implementation of a CDM project activity are lower than those that would have occurred in the most plausible alternative scenario to the implementation of the CDM project activity.
This alternative scenario may be the business-as-usual case (that is, the continuation of current emission levels in the absence of the CDM project activity), or it may be some other scenario which involves a gradual lowering of emissions intensity.
Emission reductions resulting from each project activity shall be certified by operational entities to be designated by the Conference of the Parties serving as the meeting of the Parties to this Protocol, on the basis of: ...
- Real, measurable and long-term benefits related to the mitigation of climate change; and
- Reductions in emissions that are additional to any that would occur in the absence of the certified project activity (Kyoto Protocol, Article 12(5)).
The designated operational entity selected by the 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 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 (3/CMP.1, Annex, paragraph 37(d)).
DOEs must also assess project participants' prior consideration of the CDM. If projects start on or after 2 August 2008 and have not been published for global stakeholder consultation, the DOEs must ensure project participants have informed the host party DNA and the UNFCCC secretariat of their intention to seek CDM status:
For a new project activity with a start date on or after 2 August 2008 , the project participant must inform a Host Party designated national authority (DNA) and the UNFCCC secretariat in writing of the commencement of the project activity and of their intention to seek CDM status. Such notification must be made within six months of the project activity start date and shall contain the precise geographical location and a brief description of the proposed project activity, using the standardized form F-CDM-Prior Consideration. Such notification is not necessary if a project design document (PDD) has been published for global stakeholder consultation or a new methodology proposed to the Executive Board for the specific project before the project activity start date.
If such notification has not been provided, the DOE shall determine that the CDM was not seriously considered in the decision to implement the project activity.
If the projects start date before 2 August 2008, DOE's must assess the project participant's prior consideration of the CDM using document reviews:
For an existing project activity with a start date before 2 August 2008, for which the start date is prior to the date of publication of the PDD for global stakeholder consultation, the DOE shall assess the project participant's prior consideration of the CDM through document reviews and shall satisfy following requirements:
- Evidence that must indicate that awareness of the CDM prior to the project activity start date, and that the benefits of the CDM were a decisive factor in the decision to proceed with the project.
- Evidence to support this would include, inter alia, minutes and/or notes related to the consideration of the decision by the Board of Directors, or equivalent, of the project participant, to undertake the project as a proposed CDM project activity.
- Reliable evidence from project participants that must indicate that continuing and real actions were taken to secure CDM status for the project in parallel with its implementation. Evidence to support this should include one or more of the following: contracts with consultants for CDM/PDD/methodology services, draft versions of PDDs and underlying documents such as letters of authorization, and if available, letters of intent. Emission Reduction Purchase Agreements or other documentation related to the sale of the potential CERs (including correspondence with multilateral financial institutions or carbon funds), evidence of agreements or negotiations with a DOE for validation services, submission of a new methodology to the CDM Executive Board, publication in newspaper, interviews with DNA, earlier correspondence on the project with the DNA or the UNFCCC secretariat (EB 62, Annex 13, paragraph 6).
The Executive Board has made it clear that detailed information on the demonstration of additionality and an assessment of the appropriateness of the method used to demonstrate additionality must be included in the project design document (PDD):
The Board requested DOEs to ensure that detailed information on the demonstration of additionality and the determination of baselines, including related calculations, be either integrated in PDDs or submitted as annexes to PDDs (EB 26, paragraph 90).
With a view to improving the quality of requests for registration of project activities, the Board reiterated that detailed information on the demonstration of additionality has to be either integrated in PDDs or submitted as annexes to PDDs. The Board further instructed the DOEs to ensure that validation reports include an assessment of the appropriateness of the demonstration of additionality, including documentation and other evidence provided by project participants.
The Board also clarified that requests for registration attaching a PDD and validation that report do not contain this information shall be considered incomplete (EB 27, paragraph 50).