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Submission to call for input: review of the registration and issuance process

The recommendations below focus on the voice of civil society within the CDM process. While there are opportunities for public participation throughout the CDM validation process (i.e. local stakeholder consultation when designing the project and global stakeholder consultation period), opportunities seize to exist once the validation report is submitted to the UNFCCC. If a designated operational entity decides to validate a project activity despite serious concerns by civil society, there are no further opportunities for public input. Hence, there is no official way to challenge a designated operational entity against wrong claims in a validation report or to raise concerns about the project that only appear after the last official opportunity for public input has taken place. Another concern of civil society relates to the fact that only Parties involved and three Executive Board members can trigger a review. But CDM Watch is concerned that it is not enough to rely on Parties (that hardly ever use this opportunity) and Executive Board members – although with the support of the secretariat – to ensure that for all registration and issuance requests that do not fulfill the CDM requirements, a review be requested. Yet, there is no official opportunity for civil society to raise concerns about a project activity at the stage of requesting registration. Civil society is not even notified about these final steps in the CDM registration process.

Against this background, the following recommendations are made:

1. Notification about the publication of project activities that request registration must be extended to the public. Notification must be done via mailing lists to which interested civil society actors can subscribe.
2. 10 UNFCCC accredited observer organisations or 100 individuals should be able to trigger a request for review.

The establishment of a mailing list would be a step towards the request by decision -/CMP.5 para8 to the Executive Board to enhance its communications with project participants and stakeholder. Although this request does not directly address access to information, it however implies it. Communication can only be enhanced if a minimum access to information as a basis for the communication is provided. Moreover, the notification of registration and issuance requests to the public is essential to facilitate consideration of information from stakeholders and UNFCCC accredited observers within the review process.

In anticipation of the establishment of procedures for considering appeals as requested by decision -/CMP.5 para42, the inclusion of civil society views at the stage of registration requests would also have positive effects on the efficient and timely consideration of registrations in the overall CDM process. Allowing UNFCCC accredited observers to raise concerns about situations where a designated operational entity may not have performed its duties in accordance with the CDM requirements prior to registration of a project activity, a lengthy and costly potential appeal processes could be avoided.

CDM Watch (pdf.file)

Earthjustice (pdf.file)

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