What is a Programme of Activities?
The concept of a Programme of Activities (PoA) (often called Programmatic CDM) is described in EB 47, Annex 29, paragraph 3 as follows:
A programme of activities (PoA) is a voluntary coordinated action by a private or public entity which coordinates and implements any policy/measure or stated goal (i.e. incentive schemes and voluntary programmes), which leads to anthropogenic GHG emission reductions or net anthropogenic greenhouse gas removals by sinks that are additional to any that would occur in the absence of the PoA, via an unlimited number of CDM programme activities (CPAs) (EB 47, Annex 29, paragraph 3).
In other words, a PoA is:
- A voluntary action,
- Implementing a policy, measure or stated goal,
- Coordinated by a public or private entity,
- Resulting in emission reductions or removals that are additional.
The PoA has its origins in a decision of the COP/MOP that local/regional/national policies or standards cannot be considered as CDM project activities, but project activities under a PoA can be registered as a single CDM project activity:
The Conference of the Parties serving as the meeting of the Parties, ...
- Decides that a local/regional/national policy or standard cannot be considered as a clean development mechanism project activity, but that project activities under a programme of activities can be registered as a single clean development mechanism project activity provided that approved baseline and monitoring methodologies are used that, inter alia, define the appropriate boundary, avoid double-counting and account for leakage, ensuring that the emission reductions are real, measurable and verifiable, and additional to any that would occur in the absence of the project activity (7/CMP.1, paragraph 20).
Note: At present, the Procedures for registration of a programme of activities as a single CDM project activity and issuance of certified emission reductions for a programme of activities (version 4.1) (EB 55, Annex 38) provides the current guidance and procedures applicable to PoAs and replaces both EB 32, Annexes 38 and 39. Furthermore, under paragraph 22 of these Procedures, members of the Executive Board and the DNAs of Parties involved in the PoA have the possibility to review the potentially erroneous inclusion of a CPA into a registered PoA. The procedures are set out in the Procedures For Review of Erroneous Inclusion of CPA and can be accessed here (version 3) (EB 61, Annex 22).
The erroneous inclusion of a CPA into a programme of activities registered as a single CDM project activity (PoA) means that the CPA does not meet the eligibility criteria for inclusion as specified in the CDM-POA-DD. If a DNA or a Board member indentifies information that may disqualify a CPA from inclusion or renewal of its crediting period a request for review may be lodged with the Secretary of the Board. It is then up to the discretion of the Chair of the Board to decide whether the request for review is added to the agenda of the next Board meeting.
Upon considering the request for review the Board may decide to:
- Exclude the CPA from the PoA if it was erroneously included; and
- Initiate a full review in case it determines the consideration of the request for review raises concerns regarding the processes used to include CPAs in the PoA.
Any CPA that has been excluded shall not be re-included again in that or any other PoA, or qualify as a CDM project activity. The DOE may be liable to refund any CERs gained from a erroneous inclusion (EB 61, Annex 22).
A PoA is made up of CDM Programme Activities (CPAs). Multiple CPAs can be included under a PoA at the time of registration and additional CPAs can be added at any point in the life of the PoA.
A CPA is not currently defined in the current procedures found within EB 47, Annex 29 but was defined in the previous guidance (EB 32, Annex 38) which, despite being replaced by EB 47, Annex 29, continues to provide a helpful source of information:
A CPA is a single, or a set of interrelated measure(s), to reduce GHG emissions or result in net anthropogenic greenhouse gas removals by sinks, applied within a designated area defined in the baseline methodology (EB 32, Annex 38, page 1).
EB 32, Annex 38 also provided that a PoA can involve CPAs being run in multiple countries, in which case a separate letter of approval would be required from each Party involved:
The physical boundary of a PoA may extend to more than one country provided that each participating non-annex I host Party provides confirmation that the PoA, and thereby all CPAs, assists it in achieving sustainable development (EB 32, Annex 38, paragraph 2).
This was reiterated in EB 47, Annex 29, which contemplates the possibility of a PoA being located within "several countries":
The coordinating/managing entity shall obtain letters of approval for the implementation of the PoA from each Host Party and Annex I Party involved in the PoA. (EB 47, Annex 29, paragraph 7)
The coordinating/managing entity is the private or public entity that coordinates the PoA.
A PoA is distinct from a bundle of small-scale projects, because it is possible to add new CPAs to a PoA without undertaking the validation process afresh. No registration fee is payable on CPAs which are added subsequently to validation.