Revising and withdrawing an approved methodology

In certain circumstances, the revision of an approved methodology may be required. A revision in this context is defined as:

...the modification of an approved methodology in order to improve it or broaden its scope and applicability. The revision results in the approved methodology with a new version number (EB 27 Annex 10, paragraph 3).

However, there is conflicting guidance on this point - some decisions suggest that any modification will result in a new ‘version' of the same methodology, while others suggest that only minor corrections can result in a new ‘version' and major corrections will result in an entirely new methodology:

For minor revisions and corrections a simplified procedure is foreseen: They are to be approved as "versions" rather than "revisions" as is the practice of the Board. Minor revisions include also the incorporation of a proposed new methodology into an approved methodology that requires only minor modification. The source and project participant of the incorporated methodology should be mentioned in the new version. Minor revisions (including incorporations) result in a new "version" of the approved methodology, rather than a new consolidated methodology (EB 27 Annex 10, paragraph 6).

Revisions of methodologies must be carried out in accordance with the modalities and procedures for establishing new methodologies.

Effect of revisions and withdrawals on registered project activities

Revisions and withdrawals of approved methodologies do not affect:

• Project activities that, at the time of the revision or withdrawal, have already been registered using the old methodology; or
• Project activities that, at the time of the revision or withdrawal, have already been published for public comments (as part of the validation process) using the old methodology, but only if the project is then submitted for registration within 8 months of the date of the revision or withdrawal.

This rule was first set out in 3/CMP.1, Annex, paragraph 39:

A revision of a methodology shall be carried out in accordance with the modalities and procedures for establishing new methodologies as set out in paragraph 38 above. Any revision to an approved methodology shall only be applicable to project activities registered subsequent to the date of revision and shall not affect existing registered project activities during their crediting periods (3/CMP.1, Annex, paragraph 39).

Clarification on this decision was provided by the Executive Board at EB 35:

16. In accordance with paragraph 39 of the CDM modalities and procedures, any revision to an approved methodology or tool referred to in a methodology shall only be applicable to project activities registered after the revision and shall not affect
    1. registered CDM project activities during their crediting period; and
    2. project activities that have been published for public comments for validation using the previously approved methodology or tool, so long as the project activity is submitted for registration within 8 months of the effective date of the revision.
17. Likewise, if the revision results in the withdrawal of one or more approved methodologies, the withdrawal shall not affect
    1. registered CDM project activities during their crediting periods; and
    2. project activities that have been published for public comments for validation using the previously approved methodology or tool, so long as the project activity is submitted for registration within 8 months of the effective date of the revision (EB 35, Annex 13, paragraphs 16 and 17).

As set out above, if a project activity, which has been published for public comments for validation using an old methodology, is submitted for registration within 8 months of the effective date of the revision of that methodology, that project can continue to use the old methodology.  The Executive Board clarified at EB 35 that a project will be considered to meet this deadline if the following conditions are satisfied:

1. The DOE has uploaded the request for registration using the dedicated interface of the UNFCCC CDM website before 24:00 GMT on the day of the deadline; [and]
2. Either the proof of payment is uploaded within 20 calendar days after the deadline or the payment is received within 40 calendar days after the deadline (EB 35, Annex 15, footnote 2).

Fulfilment of these conditions is verified by an automated process.

When can revisions be carried out?

The circumstances when revisions of approved methodologies can be carried out are set out in Clarifications to project participants on when to request a revision, clarification to an approved methodology or a deviation (EB 31, Annex 12; previously EB 30, Annex 1), and also in the Criteria for consolidations and revision of methodologies (EB 27 Annex 10).

A revision may be carried out when:

new or a better understanding of scientific evidence indicate that emission reductions may be over- or under estimated based on the existing approved methodology or that the reductions may not be real, measurable and verifiable;

the applicability conditions require broadening to include more potential project types or conditions for use;

there are identified inconsistencies, errors and/or ambiguities in the language and/or formulae used within or between methodologies;

there is scope for simplification and or more clarification in order to improve its user-friendliness (also to include clarifications that have been given by the Meth Panel in response to queries regarding the applicability of approved methodologies) (EB 27 Annex 10, paragraph 4).

A revision may also be carried out after a request from the COP/MOP, the Executive Board, the Meth Panel and working groups:

The revision of approved methodology may be carried out in response to requests by a project participant, relevant stakeholders, the Executive Board, the Meth Panel or Working Groups in accordance with the latest version of the procedures (EB 31 Annex 12, paragraph 5).

The revision may be carried out in response to requests recommended in the meetings by the COP/MOP, Executive Board, the Meth Panel and working groups. In addition revisions may be carried out in response to request for revisions as per the procedures for revisions (EB 27 Annex 10, paragraph 5).

It is appropriate for a project participant to request a revision when the proposed project activity is broadly similar to the project activity to which an approved methodology applies:

A request for revision is suited for situations where an approved methodology is not applicable to a project activity but the project activity is broadly similar to the project activities to which the approved methodology is applicable. Similarity is based on the nature (technology/measure) of the project activity and sources of the emissions affected by the project activity.

For example, the approved methodology may not be applicable as the source of emissions affected by the project activities are the same but the technology/measure used in the project activity is not covered under the applicability conditions; or the procedures provided in the methodology for estimating emissions from sources are not applicable because of slight variations in the approach, flow of events or structure chosen in the project activity (EB 31 Annex 12, paragraph 6).

However, if no approved methodology is appropriate for revision, then methodologies may be consolidated. The full text of the decision referring to this rule is reproduced below; however, pending clarification from the UNFCCC Secretariat, it is assumed that the word 'revision' should be replaced with the word 'consolidation', as indicated:

Should no approved methodology be appropriate, then a revision [replace with 'consolidation'?] to an approved methodologies could be requested. In this case significant changes are required to the approved methodology for it to be applicable to all possible project scenarios, without which inter alia the application of the methodology to the proposed project activity would be inappropriate, resulting in an incorrect definition of the project boundary, double counting, an inaccurate account of leakage, emission reductions that are either not real, measurable, verifiable or additional to those that would occur in the absence of the project activity (EB 31 Annex 12, paragraph 7).

A new proposed methodology will be required where the request for revision limits the ability of other projects activities to use the applicability conditions of approved methodologies:

The request for revisions shall not include changes to the approved methodology that would result in the exclusion, restriction, narrowing of the applicability conditions of the approved methodologies for other project activities. Should the request result in the above the project participant is advised to submit a new proposed methodology (EB 31 Annex 12, paragraph 8).

Project participants are discouraged from requesting revisions to more than half of the sections of an approved methodology:

In this regard, if the request for revision to an approved methodology is likely to result in the addition of new procedures or scenarios to more than half of the sections of an approved methodology, it is advisable that project participants propose a new methodology as per procedures for submission and consideration of proposed new methodology accordance with the latest version of the procedures (EB 31 Annex 12, paragraph 9).

A revision of an approved methodology need not follow a request. The Meth Panel may initiate a revision based on its experience examining submissions of new methodologies:

The Methodologies Panel may also recommend the revision of an approved methodology based on the experience gained through the examination of submissions of new methodologies in order to ensure a consistent approval process, and when doing so ensure there is a minimum of six (6) months between revisions, where possible. Information on a proposal for revision of an approved methodology shall be made available in the UNFCCC CDM web site and forwarded to the Board via list serve and to the public through the CDM news facility (EB 35, Annex 13, paragraphs 13).

Revision process

Project participants who wish to propose a revision to an approved methodology must submit the required documents to a DOE:

Project participants who intend to propose a revision to an approved baseline or monitoring methodology or tool referred to in a methodology for the Executive Board's consideration and approval shall submit to a DOE the following:

1. a form for submission of requests for revisions of approved methodologies to the Methodologies Panel (F-CDM-AM-Rev);
2. a draft revised version of the approved methodology or tool referred to in a methodology highlighting proposed changes; and
3. a draft project design document (CDM-PDD) with sections A to C completed, including relevant annexes (EB 35, Annex 13, paragraph 7).

The DOE will check the documentation and forward it to the secretariat:

Once the DOE has checked that all requirements are met and documents are complete, the DOE must send the documentation to the secretariat. The secretariat shall then send the document to the Executive Board and Methodologies Panel after checking that the DOE:

has properly filled the "CDM: Proposed revision of approved methodology form",

submitted complete documentation and preparing draft responses (EB 35, Annex 13, paragraph 8).

Public comment may then be invited:

Depending on the proposed revision of a methodology, the Methodologies Panel and or the Executive Board may decide to request the secretariat to invite public inputs on the proposed revision for a period of 15 working days (EB 35, Annex 13, paragraph 9).

The request for revision will then be reviewed by the Meth Panel:

10. One member of the Methodologies Panel shall, under the guidance of the Chair of the Panel, be selected to review the secretariat's draft recommendations. If more detailed consideration is required, the Chair may select an additional member. The selected Panel member(s) shall each be paid a one fee per Case.
11. Bearing in mind the timelines and deadlines for the consideration of documents by the Methodologies Panel and priorities set by the Board and the Chair of the Methodologies Panel, the panel shall consider the proposed revision at its next meeting, if feasible and if received by the secretariat at least six (6) weeks before the meeting (EB 35, Annex 13, paragraphs 10 and 11).

Once it has reviewed the request, the Meth Panel will make a recommendation to the Executive Board:

12. The Methodologies Panel shall recommend, based on substantiated justification, a revision to an approved methodology or tool referred to in a methodology or the continued validity of the already approved methodology, possibly with minor revisions and/or minor corrections.

14. The Methodologies Panel shall recommend to the Board whether to accept the request for revision and if it recommends approval, it shall submit a draft revised version of the approved methodology to the Board (EB 35, Annex 13, paragraphs 12 and 14).

The Executive Board will consider the recommendation and decide whether to approve the revision:

The Executive Board shall consider the recommendations for revision to approved methodologies or tool referred to in a methodology by the Methodologies Panel at its next meeting (EB 35, Annex 13, paragraph 15).

If the revision is approved, the new methodology will replace the previously approved methodology:

If the Board approves the revision of an approved methodology, this methodology shall replace the previously approved methodology. The revision shall be deemed effective 14 calendar days after the date of publication on the UNFCCC website (24h00 GMT), which shall be within five (5) calendar days after the Board's publication of the report (EB 35, Annex 13, paragraph 16).

Methodologies put ‘on hold' during the revision process

Where a significant revision is required, it may be necessary to put the use of a methodology ‘on hold':

Should an approved methodology require a significant revision, its further use shall be put on hold and its revision be undertaken in an expedited manner (EB 27 Annex 10, paragraph 7).

If the Board considers that the possible revision of the methodology could have significant implications for the use of the methodology, the Board may agree to suspend the use of the methodology, by putting it "on hold", with immediate effect (EB 35, Annex 13, paragraph 18).

Project activities that are registered or have been submitted for registration within 4 weeks of the methodology being put ‘on hold' will not be affected. Other projects, however, will not be permitted to use the methodology until a decision on the revision has been made:

Project activities using such a methodology that have not been submitted for registration within four (4) weeks after the methodology has been put "on hold", will not be permitted to use the methodology until the Board has made a decision with respect to the methodology. (EB 35, Annex 13, Section II(19))

However, if a methodology is put ‘on hold' a revised methodology must be made available within no more than 3 Executive Board meetings:

If the Board puts a methodology "on hold", in accordance with paragraph 16 above, a revised methodology should be approved no later than the third Board meeting after the methodology has been put "on hold" (EB 35, Annex 13, Section II(20)).

In addition to the above, if a revision is requested by the COP/MOP:

1. no CDM project activity may use the methodology requested to be revised; and
2. the panel/working group shall revise the methodology, as appropriate, taking into consideration any guidance received (EB 35, Annex 13, paragraph 3)

Version 9 of the Procedures for the Revision of an Approved Baseline or Monitoring Methodology by the Executive Board (EB 35, Annex 13) replaces previous versions EB 32 Annex 14 (Ver 8), EB 31 Annex 13, EB 28 Annex 16, EB 25 Annex 18, EB 23 Annex 3, EB 21 Annex 6, EB 19 Annex 3.