During this meeting, the Board will also discuss a draft procedure for the submission and consideration of requests for revision of approved baseline and monitoring methodologies and tools for large scale CDM project activities. As part of this discussion, CDM Watch strongly urges the Board to address a serious related flaw in the CDM procedures:

If the Board agrees to suspend the use of a methodology by putting it “on hold”, with immediate effect, current rules foresee that the project activities that have not been submitted for registration within four 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[1].

In other words, although the methodology is put on hold because it e.g. causes “the issuance of “artificial” CERs”, projects can still request registration within four weeks from the date the methodology was put on hold using the flawed methodology.

For the case of supercritical coal projects that were submitted under ACM0013 Ver. 2 this means that a registration request could have been submitted even after the Board had decided that the methodology Ver.2 was no longer ensuring additionality.

Having raised this issue before, CDM Watch was told that a grace period is needed to ensure investment security. However, CDM Watch does not believe that a grace period of four weeks would make any significant difference for projects that take years to complete. In the spirit of environmental integrity, revised methodologies should certainly be applicable to projects that have just entered the CDM pipeline as well as to projects that have been in the process for months.

Action to be taken by the Board: When considering the draft “Procedure for the submission and consideration of requests for revision of approved baseline and monitoring methodologies and tools for large scale CDM project activities” the Board shall make all projects subject to revised methodologies and exclude any grace periods.