Carbon Market Watch

For fair and effective climate protection.

Your Voice in the CDM

Carbon Market Watch worked hard to improve the opportunities for civil society to voice concerns about the CDM. Carbon Market Watch continues to expand these efforts for increased public participation to other carbon market initiatives.

The CDM is a complex mechanism with limited opportunities for stakeholder input. Despite the current obstacles it is important to know what possibilities for public input there are throughout the project cycle.

Many different authorities and entities are involved in implementing a CDM project. Depending on which step the project is at, there are different opportunities to raise issues. You can find more information in our CDM Toolkit available in 5 languages.

Overview of input opportunities during the project cycle

(go here to learn more about the project cycle)

1. Project Design – Preparing the Project Design Document (PDD)

Presentation of information on the essential technical and organizational aspects of the project, prepared by the developer or a hired consultant

During the preparation of a project, the developer must consult you on the design of the project. CDM projects are required to provide evidence that the project’s activities will not adversely impact local populations and other relevant stakeholders. The developer must inform all relevant stakeholders about the project through appropriate forms of media. The developer must respond to all stakeholder comments, and describe a course of action to minimize negative impacts. The outcomes of these local stakeholder consultations must be documented in the Project Design Document (PDD). Often these stakeholder consultations are not carried out adequately.

The developer must provide an assessment of the project’s environmental impacts. Depending on your national and/or regional laws, this may require an Environmental Impact Assessment involving a public comment period.

2. Host Country Approval – Letter of Approval
  • The host country DNA must approve the project and confirm that it contributes to sustainable development. You should be able to have input to this decision. If not, lobby your DNA for a more inclusive decision taking.
3. Requesting Validation – from PDD to Validation report

30 day Global Stakeholder Consultation  period

  • Before validating the project, the PDD is made available for a 30-day public comment period.

Before the validator assesses whether the project developer has complied with the key requirements in the PDD, the public has the chance to make submissions during a 30-day public comment period. During this period, you can raise your concerns to the validator about whether the project meets the validation requirements and thus whether it should be approved. That is why validation is a crucial point in the project approval process for civil society actors. Learn more

 

4. Registration by the CDM Executive Board

Registration by the Executive Board is automatic eight weeks after the validation report has been received, unless one of the countries involved in the project, or at least 3 members of the Executive Board request a review. This theoretically provides civil society actors with a last chance to influence a project’s approval.

  • If you believe a project in your region should not be approved, you should lobby your government to request a review and inform CDM Watch.

5. Verification, certification and issuance of emission reductions

Similar to the review process at registration stage, the process for issuance also foresees that a project participant, one of the governments involved or three members of the Executive Board can request a review. This means that the verification and issuance process also allows for an opportunity to influence a CDM project after registration.

If you believe that the project is not reducing emissions in the way it claimed it would, you can contact the verifier and CDM Watch with that information.

  • If you believe that the project is not performing in the way the developer said it would, you should contact the verifying DOE and CDM Watch.

6. Renewal of the crediting period

The new PDD must be made public for comments for a period of 4 weeks

Criticism about current stakeholder engagement rules

Although it is a key requirement in the CDM process cycle, the stakeholder consultation process has so far been a mere formality. Often communities impacted by CDM projects are not informed about CDM projects or not given an accurate account of expected impacts. Moreover, civil society has now way of knowing about the short 30-day public commenting period that is only announced online and only allows submissions in English.

Currently, there is no opportunity for civil society to raise concerns once a project has been registered and is operational. Robust grievance mechanisms both, at international as well as national and local level must be put in place to ensure that those who may be negatively impacted by CDM project activities can raise their concerns and have them addressed in a timely manner. More about public participation