On behalf of the accredited organization German Forum Environment & Development, Carbon Market Watch, a project by Nature Code, welcomes the opportunity to provide its views on the review of the modalities and procedures (M&P) of the Clean Development Mechanism (CDM).

Despite the uncertain future of the CDM, we believe that it is important to address its flaws and improve its rules for the following reasons:

1. Its rules have served and will continue to serve as a blueprint for other carbon market mechanisms. Because the CDM is used as a reference by many other emerging schemes, it is vitally important that its rules are well -designed and have integrity.
2. Despite the imbalance between supply and demand, a significant number of credits are expected to be used by Parties that plan to join a second commitment period. If these credits come from projects with poor environmental integrity, the CDM will continue to undermine the already weak emissions reduction targets.

We urge Parties to strengthen the social and environmental integrity of the CDM and to address, as a matter of priority, the following issues:

1. Fundamentally reform additionality requirements
2. Shorten length of crediting periods
3. Ensure that all CDM Projects uphold human rights
4. Improve the CDM’s contribution to sustainable development
5. Strengthened Civil Society Participation in the CDM process
6. Address conflict of interest of DOEs
7. Establish a communications channel for case specific matters
8. Set-up a Grievance Mechanism
9. Improve the constitution and conduct of the CDM Executive Board and supporting bodies

Read the full submission here.