The Executive Board established in EB 13, paragraph 39 a sequence of steps for the validation of a proposed CDM project activity. In summary, in order to validate a project activity, the DOE must:
- Make the CDM-PDD publicly available and receive comments from stakeholders;
- Check that validation requirements have been met;
- Determine whether the project should be validated;
- Inform project participants of the decision;
- Submit a request for registration to the Executive Board (if the proposed project activity is determined to be valid); and
- Make the validation report publicly available.
The steps for validation are as follows:
Step 1: The DOE is to make the CDM-PDD publicly available and receive comments in accordance with sub-paragraphs 40 (b) and (c) of the CDM modalities and procedures;
Step 2: The DOE is to check that validation requirements in paragraph 37 of the CDM modalities and procedures have been met after having reviewed the CDM project design document (CDM-PDD) and any supporting documentation (including ensuring that the baseline and monitoring methodologies used are approved by the Board);
Step 3: After the deadline for receipt of comments, the DOE is to make a determination as to whether the project activity should be validated;
Step 4: The DOE is to inform project participants of its determination on the validation of the project activity;
Step 5: The DOE is to submit to the Board, if it determines the proposed project activity to be valid, a request for registration in the form of a validation report. Before submitting the request for registration, the DOE has to have received the written approval(s) referred to in paragraph 40 (a). The request for registration (using the form F-CDM-REG) shall include, inter alia, the project design document, the written approval of the host Party, and an explanation of how the DOE has taken due account of comments received. If the DOE determines that the proposed project activity is not accepted, it shall, in addition to actions identified in paragraph 40 (e), forward its determination and the documentation considered to the Board. A list of proposed project activities that have not been accepted by DOEs, including supporting documentation, will be made available to DOEs and the Board;
Step 6: The validation report is to be made publicly available (simultaneously with request for registration) (EB 13, paragraph 39).
The Executive Board has also clarified that in issuing the validation report, the designated operational entity (DOE) must confirm the likelihood of the project achieving additional emission reductions:
174. The DOE shall provide either:
a. A positive validation opinion in its validation report that is submitted as a request for registration; or
b. A negative validation opinion in its validation report explaining the reason for its opinion if the DOE determines that the proposed CDM project activity does not to fulfil applicable CDM requirements. In accordance with paragraph 40 (e) (ii) of the CDM Modalities and Procedures the DOE shall provide this validation report to the project participants, and in accordance with paragraph 18 of the .Procedures for processing and reporting on validation of CDM project activities. (EB 50, annex 48) the DOE shall notify the CDM Executive Board that such a validation report has been issued.
175. The opinion shall include at least the following:
d. A statement on the validation of the expected emission reductions (EB 51, Annex 175).
EB 11, Annex 6 had previously confirmed the same:
In issuing a validation opinion in the validation report regarding paragraph 37 (d) of the CDM modalities and procedures the DOE shall include a statement of the likelihood of the project activity to achieve the anticipated emission reductions stated in the CDM-PDD. This statement will constitute the basis for the calculation of the registration fee (EB 11, Annex 6, paragraph 2).
The process described above replaces earlier guidance the Executive Board in EB 8, Annex 3, paragraph 3. The key changes were:
• New order of steps: the CDM-PDD is now made publicly available at the start of the process, and the DOE checks validation requirements during the 30-day period for providing comments (previously this order was reversed); and
• Clarification of the process for rejected project activities: see Step 5.
Note: Whilst EB 54, Annex 28 has replaced EB 11, Annex 6 and EB 8, Annex 3, the previous procedures remain informative and may provide guidance where the new procedures are otherwise silent.
Note: DOEs are required to effectuate the validation process in accordance with the CDM Validation and Verification Manual (VVM) and the requirements based on paragraph 37 of the CDM modalities and procedures. The latest version of the VVM (1.2), a comprehensive guide that is aimed to assisting DOEs in achieving quality and consistency in their validation and verification work, can be accessed here (EB 55 Annex 1).