CDM Watch welcomes the opportunity to provide its views to the CDM Executive Board on areas and means for direct communication of stakeholders and the Board. We wish to highlight possibilities for improvement of the accessibility and facilitation of communication especially between civil society actors and the Board.
Communication between civil society representatives and the Board mainly happens via means of public participation in the CDM process cycle. Therefore, this submission focuses particularly on how to improve the public participation as a means to improve direct communication with the Board.
Over the last years, CDM Watch has engaged with a wide range of civil society actors with the aim to coordinate public participation and communication with the Board. However, a significant number of obstacles remain within the CDM procedures.
In order to improve communication between civil society and the Board we would like to recommend in particular the following:
- Set-up email notification systems for registration, issuance and methodology processes as well as for all public participation procedures that depend on a certain period of time
- Further improve of the user-friendliness of the UNFCCC CDM website including the translation into all official UN working languages
- Make available essential documents of CDM projects (at least the PDD and the EIA) in the language(s) of the host country
- Make available hard copies of the translated PDD to affected communities
- Ensure that all supporting documents are uploaded prior to the start of the public commenting period
- Allow submissions of comments in the language(s) of the host country
- Allow delayed submissions of comments if the delay is due to a reasonable justification
- Increase the public commenting period for large projects
- Increase the public commenting period on new methodologies
- Introduce a mechanism where concerns about CDM projects can be submitted at any time