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TÜV NORD CERT A TÜV NORD Company

TÜV NORD CERT A TÜV NORD Company. Validation perspective for PoA Rainer Winter, Jun Wang; TÜV NORD CERT GmbH 2010-05-10. 1 Introduction. 2 Validation of PoA. 4 Challenges and Problems. 5 Conclusion. Inhalt. 3 TN Experiences. 1 Introduction. PoA Scales up CDM Project Portfolio

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TÜV NORD CERT A TÜV NORD Company

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  1. TÜV NORD CERT A TÜV NORD Company Validation perspective for PoA Rainer Winter, Jun Wang; TÜV NORD CERT GmbH 2010-05-10

  2. 1 Introduction 2 Validation of PoA 4 Challenges and Problems 5 Conclusion Inhalt 3 TN Experiences

  3. 1 Introduction PoA Scales up CDM Project Portfolio • By 05/05/2010: • 3 PoAs registered • 1 PoA Correction requested • 40 PoAs under validation • Host Countries involved • Southeast Asia (15) • India (8) • China (6) • Latin America (7) • Africa (7) • Middle East (1) Sectors include: • Scope 1 Energy industries (renewable - / non-renewable sources) • Scope 2 Energy distribution • Scope 3 Energy demand • Scope 4 Manufacturing industries • Scope 7 Transport • Scope 13 Waste handling and disposal • Scope 14 Afforestation and reforestation • Scope 15 Agriculture

  4. 2 Validation of PoA • Mandatory PoA validation requirements: • Clean Development Mechanism Validation and Verification Manual (v01.1 EB51 Annex 3, esp. para 164 – 167) • Registration of a programme of activities as a single CDM project activity and issuance of CERs for a PoA (v03, EB47 Annex 29) • Procedures for review of erroneous inclusion of a CPA (v01, EB47 Annex 30) • Procedures for approval of the application of multiple methodologies to a programme of activities (v01, EB47 Annex 31) • Guidance for determining the occurrence of de-bundling under a programme of activities (PoA) (v02, EB47 Annex 32) • PoA-DD and CPA-DD forms and requirements on http://cdm.unfccc.int/Reference/PDDs_Forms/PoA/index.html • Useful Guidelines: • Guidelines on Project Design Documents (PDDs) on http://cdm.unfccc.int/Reference/Guidclarif/pdd/index.html • General guidelines for sampling and surveys for small-scale CDM project activities (v01, EB50 Annex 30)

  5. 3 TN Experiences

  6. 3 TN Experiences Different section designs of PoA-DD, CPA-DD and normal PDD

  7. 3 TN Experiences • Special focus (EB51 Annex3, para 165-167) • Operational and management arrangements for the PoA(refer to EB47 Annex 29 para 4 (i) ) • CME shall have control of all records and information of CPA implementation • CME shall be able to ensure each CPA operation is in accordance with the specific requirements of the PoA. • Eligibility Criteria (EC) for CPAs(refer to EB47 Annex 29 para 12 (b) ) : • Additionality demonstration of CPA and criterion (incl. expected supporting documents necessary at the stage of CPA inclusion) (refer to EB47 Annex 29 para 4 (e) ) • Applicability of the applied methodology shall be specifically defined for the project type, technology and measures • Validation of CPAs: • Complies with the EC specified in the POA-DD • All supporting documents to demonstrate CPA EC compliance shall be checked.

  8. 3 TN Experiences • Additional requirements compared to stand-alone CDM (EB47 Annex29): • LOA requirements: • CME should obtain letters of authorization of its coordination of the PoA from each Host Party • LoA should confirm that the project is a ‘programme of activities’ • Identification of the CME and PoA participants: • Shall be included clearly in section A.3 of the POA-DD • A transparent record keeping system for each CPA: • to ensure status of verification can be determined anytime for each CPA • A system/procedure to avoid double accounting • CPA operators’ awareness and agreement on PoA • A statistically sound sampling method/procedure for verification • If the CME does not wish to have all CPAs verified

  9. 3 TN Experiences Definition of PoA starting date? Only when uploading for requesting registration of PoA, requirements can be found from the UNFCCC website interface that: “In case of small scale PoA, the start date of lifetime of the PoA must be at least 4 weeks after the estimated registration submission date, for large scale at least 8 weeks after the estimated submission date. ”

  10. 4 Challenges and Problems • More Documentation and Procedural Work • 3 DDs • Not only consistency within one PDD, but also within 3 DDs • Much more supporting documents: • From 500 pages to 4GB • More requirements on monitoring system: • E.g. Internet-based database and monitoring system • Design of the software needs to be checked ! • 2 Validation Reports • More than 200 pages PoA VR • More than 100 pages CPA VR

  11. 4 Challenges and Problems • 2) Liability Issue for DOEs • According to EB47 Annex 30 para 2: • “If a DNA of a Party involved in the PoA or a Board member identifies any error, within one year after the inclusion of CPA into a registered PoA or six (6) months after the issuance of CERs for that CPA, whichever is the later, that disqualifies a CPA from inclusion in the PoA, the Secretary of the Board shall be notified” • Definition of “any error”? • The missing “1st ”, shall be • “… six (6) months after the 1stissuance of CERs…” • Otherwise, can be interpreted until • “the six months after the LAST Issuance of CERs AT THE END OF THE CREDITING PERIOD, e.g., end of the 21st year !

  12. ! PoA Validator DOE Cancellation Account CPA CPA CPA CPA Within 30 days, Validator DOE shall payback all CER issued by (perceived) erroneously included CPA 4 Challenges and Problems 2) Liability Issue for DOEs (continued) • According to EB47 Annex 30 para 11 (b): • “The DOE that included the CPA, shall acquire and transfer, within 30 days of the exclusion of the CPA, an amount of reduced tonnes of carbon dioxide equivalent to the amount of CERs issued to the PoA as a result of the CPA having been included, to a cancellation account maintained in the CDM registry by the Executive Board. ”

  13. 4 Challenges and Problems 2) Liability Issue for DOEs (continued) • Example: • CERs per CPA: 60,000 per annum • PoA duration: 10 (max. 21 years) • CER price: 10 €/CER • Liability per CPA: 6,000,000 € (max. 12,600,000 €) • Number of CPAs / PoA: 10 • Total Liability: 60,000,000 € (max. 126,000,000 €) 13

  14. 4 Challenges and Problems • 3) Multiple Methodologies combination • Longer project cycle until registration • 4) Uncertainty of the Sampling Methods • Guidance only applicable for SSC PoA • Data sampling vs. onsite sampling need further guidance

  15. 5 Conclusion • PoA is still at a very early implementation phase. • Knowledge about the PoA is not yet widespread available. Experiences from existing PoAs are still very limited. • Specific guidance is still to be developed by the UNFCCC. • PoAs require specific knowledge and expertise on the validators side (e.g. procedural requirements, sampling, monitoring) which need to be build up worldwide. 15

  16. 5 Conclusion • The PoA enables project activities which can not be carried out under the “normal” CDM due to costs and administrative hurdles. • PoA Projects are usually highly sustainable • The Liability involved can lead to bankruptcyof the validating DOE • The full PoA potential can only be tapped if the liability risks for the DOEs will be reduced significantly. • The No. of PoAs under validation does not mean that they all will work. The real liability starts after registration – during inclusion of CPAs.

  17. TÜV NORD CERT A TÜV NORD Company Thanks for your attention! TÜV NORD CERT GmbH Jun Wang Langemarckstraße 20 D-45141 Essen Fon +49 (201) 825-2778 Fax +49 (201) 825-2139 jwang@tuev-nord.dewww.tuev-nord.de www.global-warming.de TÜV NORD CERT GmbH Rainer Winter Langemarckstraße 20 D-45141 Essen Fon +49 (201) 825-3329 Fax +49 (201) 825-2139 rwinter@tuev-nord.dewww.tuev-nord.de www.global-warming.de

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