CDM Executive Board members usually call people not part of the inner CDM circle the ‘outside world’. Communication between these two worlds is often not as constructive as would be necessary to ensure the integrity of the CDM. During this upcoming meeting Board members have the opportunity to improve this situation by strengthening guidance on how local stakeholder consultation must be conducted. To ensure effective public engagement, the Board also needs to clarify modalities and procedures on how the ‘outside world’ can communicate concerns about the implementation of CDM rules.

Time to improve Local Stakeholder Consultation

Despite the controversy, including accusations of human rights abuses, surrounding the Aguan CDM project in Honduras, the CDM Executive Board registered the project at their last meeting. The Board concluded that the concerns about the adequacy of the local stakeholder consultation, as extensively described in our letter to the CDM Executive Board of June 2011, were not substantiated and that the project complied with all requirements of the validation and verification manual (VVM). The Board’s decision to register the project despite the poor local consultation draws attention to the fact that an urgent reform of the validation requirements is needed.

CDM Watch recommends that the CDM Executive Board adopt clear rules about how local stakeholder consultation should be conducted when discussing the new draft validation and verification standard[1] at their upcoming meeting. In our response to the public call for inputs on the validation process we provided detailed recommendations and highlight that guidance on the following is urgently needed:

• How local stakeholders are to be informed regarding stakeholder consultation.
• The number of stakeholder meetings that have to be conducted.
• How DOEs should assess stakeholder consultations.

Listen to us! Communication with Stakeholders

In Cancun, Parties requested that the CDM Executive Board enhance direct communication with stakeholders on issues related to registration of project activities. At its last meeting, the CDM Executive Board responded to this request by adopting new modalities and procedures for direct communication with stakeholders[2]. These procedures are supposed to enhance communication. CDM Watch was all the more puzzled when our latest submission offering additional input to the review of the Nabha Power Limited Project was not accepted by the UNFCCC Secretariat with the explanation that it was not possible to accept the input under the new revised rules. We were informed that letters related to project activities are no longer permitted. This despite the fact that the new modalities specify that “the objectives of communication with the Board initiated by stakeholders on policy are to provide stakeholders with a forum where they can communicate to the Board their views on CDM rules and their implementation”. We were further told that in the future, the new modalities and procedures only allow for input related to policy. This is not acceptable.

Any legitimate registration procedure must provide for a communication channel that allows for input that aims to strengthen the environmental integrity of specific projects and to highlight contentious projects that do not comply with CDM rules. To prohibit comments free from commercial interests from providing additional information risks compromising the environmental integrity of the CDM. It also increases the risk that projects that do not comply with CDM rules are registered without scrutiny.

CDM Watch recommends that the CDM Executive Board clarifies the implementation rulesof the new modalities and procedures for direct communication with stakeholders. In particular the Board has to ensure that public input on specific projects continues to be allowed.