Public availability of the CDM-SSC-PDD
The simplified modalities and procedures for small-scale projects require designated operational entities (DOEs) to publicly display the CDM-SSC-PDD so that comments can be received from stakeholders:
The designated operational entity shall:
- In accordance with provisions on confidentiality contained in paragraph 27 (h) of the CDM modalities and procedures, make publicly available the project design document (4/CMP.1, Annex II, paragraph 23(b)).
The PDD must be made available for 30 days:
The designated operational entity shall:
- Receive, within 30 days, comments on the validation requirements from Parties, stakeholders and UNFCCC accredited non-governmental organizations and make them publicly available (4/CMP.1, Annex II, paragraph 23(c)).
Procedures for public display
At EB 50, the Executive Board agreed to revised Procedures for processing and reporting on validation of CDM project activities, which replace Procedures on public availability of the CDM project design document and for receiving comments as referred to in paragraphs 40 (b) and (c) of the CDM modalities and procedures. The revised procedures also clarify that paragraph 6 replaces the Board's guidance contained in EB 34, paragraph 20 and that paragraph 8 replaces the provisions of EB 30, paragraph 41.
The procedures provide the following:
- DOEs shall make PDDs for non A/R project activities, non A/R programme of activities, small scale A/R project activities, and small scale A/R programmes of activities publiclyavailable on the UNFCCC CDM web site for a period of 30 days after comments have been invited from local stakeholders and appropriately taken account of.
- DOEs shall make PDDs for large scale A/R project activities and large scale A/R programme of activities publicly available on the UNFCCC CDM web site for a period of 45 days after comments have been invited from local stakeholders and appropriately taken account of.
- The DOE shall, through a dedicated interface on the UNFCCC CDM web site, submit the following information to be made publicly available:
- The name of the proposed CDM project activity or programme of activities;
- The Host Party/ies of the proposed CDM project activity or programme of activities;
- The estimated annual emission reductions indicated in the PDD, or in the case of programme of activities the estimated annual emission reductions of all specific CPA-PDDs being made publicly available;
- The approved methodology/ies being applied by the proposed CDM project activity of programme of activities;
- Reference to any previous publication of the PDD for public comments on the UNFCCC CDM website;
- The proposed start date and length of the first crediting period;
- The PDD to be made available on the UNFCCC CDM web site.
- The "Procedures for the revision of an approved baseline or monitoring methodology by the Executive Board" and the "Procedures for the revision of an approved small scale methodology by the Executive Board" provide a grace period for the submission of project activities for registration, when using a revised approved methodology. In cases where a PDD of a project activity applying the previous version of the approved methodology was published for global stakeholder consultation, but has not been submitted for registration within this grace period, project participants shall revise the PDD using the revised version of the methodology. The revised PDD shall not be republished for global stakeholder consultation prior to the submission of a request for registration, unless otherwise stated by the Board when it approves the revised methodology. Similarly, it is not required to republish the PDD for global stakeholder consultation in cases when project participants are required to use elements of a revised version of a methodology (i.e. in the case of an approved deviation).
- Paragraph 37 of the CDM modalities and procedures requires the DOE to have a contractual relationship with the project participants. Upon making the PDD available for global stakeholder consultation the DOE shall indicate with which of the project participants listed in the PDD it has a contractual relationship for the purposes of this validation activity (note that in some cases, tri-partite contracts for validation may exist amongst a DOE, a project developer and an organisation or institution which may provide funding or advice. The advisory or funding body in this case would be a non-project participant. The DOE would have no obligation to indicate that it has a contractual relationship with non-project participants).
- When submitting a request for registration all of project participants with a contractual relationship must still be listed in the PDD, unless they have provided a letter of voluntary withdrawal from the project activity. Project participants who are listed in the PDD submitted for global stakeholder consultation but who do not have a contractual relationship with the DOE for the purposes of the validation activity may be removed from the PDD which is submitted for registration.
- A DOE may recommence the validation activity through a new or revised contract with a different set of project participants by:
- In case the DOE is accredited for all sectoral scope(s) to which the proposed project activity is linked through the application of baseline and monitoring methodologies, the secretariat, through the CDM information system, makes automatically available on the UNFCCC CDM web site the PDD submitted by the DOE. The period for submission of comments shall commence at 00.00 GMT subsequent to the publication of the PDD. The information system will inform the DOE of the location of the PDD on the UNFCCC CDM website and the opening and closing dates of the period for public comments.
- In case the DOE is not accredited for all sectoral scope(s), the secretariat shall determine within three days whether the proposed project activity has been accepted as a witnessing opportunity. If it determines that the proposed activity has been identified as such an opportunity, it clears the proposed activity for treatment by the information system as described in paragraph 7 above. If it determines that the proposed activity has not been accepted as a witnessing opportunity, it will initiate appropriate steps within the accreditation procedure.
- Parties, stakeholders and UNFCCC accredited observers may submit comments on the validation requirements.
- Such comments shall be submitted to the DOE through the UNFCCC secretariat in English via a dedicated interface on the UNFCCC CDM website.
- Comments should provide the name and contact details of the individual or organization on whose behalf they are submitted. The DOE should check the authenticity of this information, in case of doubt.
- Comments submitted in accordance with paragraph 10 shall be made available by the UNFCCC secretariat on the webpage where the PDD is displayed and shall be removed if the DOE determines the information not to be authentic in accordance with paragraph 10 above.
- DOEs shall acknowledge receipt of all comments submitted and made available to them via the UNFCCC CDM website and take account of such comments in conducting validation of the proposed CDM project or programme of activities.
- Six (6) months subsequent to the end of the period for submitting public comments for each proposed CDM project activity or programme of activities the DOE shall provide, via the CDM information system, an update of the status of its validation activity, unless the project activity or programme of activities has been submitted for registration.
- This update shall indicate one of the following status:
- The validation contract has been terminated - in which case a reason for this termination shall be provided to the Executive Board and UNFCCC secretariat on a confidential basis;
- A negative validation opinion has been issued;
- The DOE has raised one or more corrective action requests or clarification requests for which no response has been received - in which case the DOE shall provide a summary of the issues raised and update or reconfirm the status of its validation activities on three (3) monthly intervals thereafter;
- The DOE has finalized a positive validation opinion with the exception of the receipt of a valid letter of approval from one or more Party/ies involved - in which case the DOE shall indicate which Party/ies involved;
- Validation activities are ongoing and no corrective action or clarification requests have yet been sent to the project participants; in which case the DOE shall provide an explanation length of time taken and update or reconfirm the status of its validation activities on three (3) monthly intervals thereafter. (EB 50, Annex 48)
This public display of, and receiving of comments on, the PDD of a project is sometimes referred to as the Global Stakeholder Process or GSP, although this term is not used in the text of any official rules. The term Global Stakeholder Process can be contrasted to the requirement to consult local stakeholders on the impacts of a CDM project in the area in which it will be developed, which is a requirement for validation.
Requirement to publicly display amended PDD
When certain major changes are made to a PDD, such as a switch in the methodology which is to be applied, the DOE is required to make the amended version of the PDD publicly available for comment again:
- The Board agreed that in cases where during validation of a project activity the project participants wish to change the methodology applied from one approved methodology to another after the PDD was available to the public for comments (note the PDD is to be made public as received from project participants), the DOE shall make publicly available again, for 30 days, the CDM-PDD in accordance with paragraph 40 (a) and (b) of the modalities and procedures for the CDM.
- The Board agreed that in cases where during validation of a project activity the project participants wish to change the version of a methodology applied due to the expiry of the version originally applied after the PDD was available to the public for comments (note the PDD is to be made public as received from project participants), the DOE shall make publicly available, for 30 days, the CDM-PDD in accordance with guidance specified in the corresponding revised methodology (EB 25, paragraphs 92-3).
The Executive Board clarified the meaning of paragraph 93 at EB 27:
The Board clarified the application of paragraph 93 of the twenty-fifth meeting of the Board, as follows:
- In cases where during validation of a project activity the project participants have to change the version of a methodology applied due to the expiry of the version originally applied after the PDD was available to the public for comments (note the PDD is to be made public as received from project participants), the DOE shall make publicly available, for 30 days, the CDM-PDD unless otherwise specified in the corresponding revised methodology.
- The DOE shall make publicly available, for 30 days, the CDM-PDD unless otherwise specified in the corresponding revised methodology if the project participant make this change within the grace period (EB 27, paragraph 29).
Again, while this decision does not specifically refer to small-scale projects, it can be assumed that corresponding requirements apply to the CDM-SSC-PDD.