Reality Check Mexico: Who participates in the CDM? (Watch This! #2)

By Eduardo Bohórquez and Bruno Brandão, Transparencia Mexicana (Transparency International national chapter)

Transparencia Mexicana analysed how all Project Design Documents for CDM projects in Mexico report about local stakeholder consultations. The results revealed that a lack of regulation and guidelines affects the quality of consultation processes, the reporting of results and the possibilities for stakeholders to intervene in the approval and accreditation of CDM projects in Mexico. The study also indicates that it is essential to ask who participates in these consultations – that is, what type of stakeholders are being listened to.

 The Clean Development Mechanism has frequently been criticized for its lack of proper public consultation. It is often argued that a lack of specific guidelines and regulations contributes to insufficient, inadequate or even forged processes of consultation. However, these critiques tend to be based upon assumptions or the experience of a limited number of cases. Broad-based, empirical data has been missing from the debate.

Transparencia Mexicana took the decision to launch a research program to address this issue and collect empirical evidence from a vast range of cases. The research is part of Transparency International’s Climate Governance Integrity Programme and aims to understand the interactions and relationships among the actors engaged with and affected by CDM projects. After a decade of work in the field of corruption, we understand that risks for integrity arise from the quality of the institutions as much as from the quality of the interactions and relationships that these institutions establish. In the first exercise within this new research program, we analysed the totality of Project Design Documents (PDDs) ever produced for CDM projects in Mexico (at the time of research, in June 2012, there were 150 PDDs, including registered, rejected, under review and withdrawn projects).

These initial results reveal that a lack of proper regulation and guidelines affects the quality of the consultation processes, the reporting of results and the possibilities for stakeholders to intervene in the approval and accreditation of CDM projects in Mexico. Our study thus supports with empirical data the criticism that is often expressed in relation to CDM consultation processes. However, the data produced by this study can do more than that. More than revealing how consultation processes are truly undertaken, they can also provide guidance as to what sort of interactions among stakeholders these processes can generate.

As mentioned above, Transparencia Mexicana works according to the premise that integrity analysis should highlight not only the quality of institutions, but also the quality of the interactions and relationships that these institutions create. Although we cannot yet corroborate these conclusions with in-depth analyses, it is worth mentioning that mitigation measures tend to be requested when specialized authorities are involved in the consultation process and interact with members of local communities.  Mitigation requests, in contrast with compensation requests, usually reflect broader knowledge and understanding by the public of CDM projects’ real impacts.

We believe that the interaction of distinct sections of the public is a crucial aspect in the design of consultation processes. Consultations should enable and promote interaction among local affected communities, academics, media, public authorities (particularly specialized agencies), project developers and consultants. This way it can promote the exchange of information at multiple directions, as not only local communities can learn from the so-called experts, but also the opposite is often the case. It is not rare that academics, media and public authorities come out of the encounter with local communities with a refined perspective over their objects of analysis.

Moreover, the encounter of distinct types of stakeholders can promote the aggregation of interests and, therefore, the creation of alliances with stronger persuasive capacity among those that are often the weaker side of the chain. This encounter does not mean that the consultation mechanism should ignore the specific needs of distinct publics and the limitations of certain actors for adequate participation. The design of consultation processes should take into account the unequal capacities among actors and aim to mitigate these unbalances. Very often these inequalities result in manipulation and exploitation and it is virtually impossible to completely avoid such behaviours.

However, an appropriate consultation mechanism that brings together distinct sections of the public can help by bringing attempts of manipulation and exploitation to broad daylight, within an institutionalized space of participation.


The study addresses three main questions concerning public participation and CDM projects in Mexico:

1)      How is the consultation process conducted?

2)      How are the results of the consultation process presented in the PDDs?

3)      How does the consultation process influence the approval and accreditation of the projects?

Initial key findings of the research:

  • Project developers and consultants have full discretion over design and undertaking of consultation with stakeholders: The most popular type of consultation is through public assembly (31%), but there were also cases of projects conducting direct interviews (3%), surveys (2%) and calls for comments (3%). The majority of the cases, however, opted for a combination of these modalities of consultation (61%).
  • Reporting of the results and characteristics of the consultation is generally very poor: Only 64% of the projects state that an attendee list (or participants list in the case of calls for comments) has been produced. From this total only 45% actually attach or reproduce the list in the PDD. Added to that, only 27% register the existence of meeting minutes, only one case confirms the existence of signed minutes, and none actually attach or reproduce the minutes. Finally, only 50% of the documents have a record of the questions and answers voiced during the hearings.
  • Very few documents actually record requests from the public: only 10% with compensation and 7.3% with mitigation requests. This could be due to several factors: insufficient and/or inadequate channels to convey comments; a lack of clarity for the public that their participation comprises more than questioning and commenting and that they can present demands; or that stakeholders do not have sufficient information about the project to be aware of their potential consequences at that time.



CDM consultation process is essential for a legitimate mechanism and the findings of the study show that the rules/guidance are insufficient and needs urgent reform. Transaction costs and the types of projects should of course be taken into consideration when designing new guidelines and regulation of CDM consultation processes. It is nevertheless our understanding that, in order to really fulfil its purpose, the CDM consultation process should be regarded as a platform for the encounter of distinct types of knowledge and interests.


Transparencia Mexicana (TM) was founded in 1999 as the national chapter of Transparency International (TI), the global coalition against corruption. TM approaches corruption from a holistic standpoint, engaging with public and private actors to reduce corruption by creating changes in the institutional and legal framework of the Mexican state. 


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