7th Joint Coordination Workshop “ Improving efficiency in the operation of CDM ” - DOE Viewpoints

1. DOE/AIE Forum | Werner Betzenbichler | March 2011 7th Joint Coordination Workshop“Improving efficiency in the operation of CDM”- DOE Viewpoints

2. Topics tobetouched • DOEs perspective on the recent changes • Positive and negative impacts • Further improvements needed

3. Which factors are most important when defining efficiency? • Speed • Quality • Comparability • Fairness / Equal Treatment • Integrity • Reliability

4. Remember the Objectives A market-based mechanism for a cleandevelopment Market requires calculable conditions (costs, return, time horizon, legislation) on project basis A clean development should deliver measurable results on national and global basis

5. DOEs are exposed to market conditions --> need for calculable conditions • Own costs (time efforts, required human resources, other costs) • Return --> marketable prices • Time horizon --> dispatching of resources, receiving of income • Legislation --> liabilities and/or penalties, business license / accreditation • Interference with other businesses

6. Impacts of recent changes • Changes in Procedures for Completeness Checks • More predictability of time schedule of first round (+) • Lower likelihood for reviews on minor issues (+) • No effective time reduction in case of identified issues, rather an extension (-) • Continuing dependence on review quality (±) • Continuing unbalanced requirements on technical expertise (±)

7. Impacts of recent changes (2) • Changes in Procedures for Requests for Reviews • Reduced predictability of time schedule (-) • De-linking from EB meeting schedule (+) • Inclusion of a second opinion (+)

8. Impacts of recent changes (3) • Accreditation Standard 2.0 • Improved guidance to DOEs and AT (+) • Safeguards market fairness (+) • Way to improve overall quality (+) • Reduction of available human resources (-) • Missing „permeability“ to qualify as auditor/expert for complex technical areas (-)

9. Recent deliberations • Direct communication • Important to accelerate whole process • Requires clear allocation of projects with secr. over the whole registration or issuance process • Establish contact persons for projects within secr. • Establish contact persons for DOEs within secr. • Recognition of improvements with regard to DOE interaction (responses on extranet, direct interaction with AP)

10. Recent deliberations (2) • PoA • Recent situation makes PoA unattractive • More responsibility (and liability) to Coordinating Entity • CPA inclusion and verification by CE, DOE assessment as it were accreditation • Procedures for erroneous inclusion at a manageable level also considering possible impacts at a reasonable ratio

11. Further improvements needed • Excess liability for DOEs • Recent situation makes DOE business unattractive • Penalty and not a liability issue • Penalty depends on impact not on mistake • Penalty in addition to accreditation threats • Based on presumptions at the time of Marrakesh which may not be valid any longer

12. Further improvements needed (2) • Electronic means to accelerate the process • Electronics forms e.g. for monitoring reports and verification reports (compare EU-ETS) • Completeness checks by software • Harmonization of AT performance • Complaints on arbitrary interpretation of regulations • Consistency among DOEs requires consistency among ATs

13. Werner BetzenbichlerChair of the DOE/AIE Forumon behalf of TÜV NORDDesignated Operational Entities and Independent Entities Associationc/o BeCe Carbon Experts GmbH ▪ Bahnhofstraße 7 ▪ 85354 Freising ▪ Germany ▪ Werner.Betzenbichler@bece-experts.com