Carbon Market Watch Submission A6.4-MEP013-A02

The document critiques the draft methodology for energy efficiency in household cooking, arguing that while it improves upon the legacy AMS-II.G methodology, it still contains critical flaws regarding the fraction of non-renewable biomass (fNRB), usage rate reporting, and the frequency of Kitchen Performance Tests (KPTs). Carbon Market Watch advocates for the exclusive use of Ghilardi & Bailis 2024 values for fNRB, a 50% cap on survey-only usage reporting, and annual or quarterly KPTs to prevent over-crediting.

• The draft methodology's approach to the fraction of non-renewable biomass (fNRB) undermines conservativeness because 46 of 72 national values are inflated relative to the MoFuSS data without justification, instead relying on the outdated CDM TOOL33.
• The draft allows projects to claim stove usage rates as high as 90% based on minimal administrative efforts like distributing flyers, despite literature suggesting actual adoption and usage rates typically range between 50% and 75%.
• Survey-based reporting for stove usage is considered fundamentally flawed due to social desirability bias, where recipients of subsidized stoves overreport usage to the providing organization.
• The proposed biennial frequency for Kitchen Performance Tests (KPTs) is deemed insufficient to capture stove degradation and seasonal fuel patterns, creating a window for over-crediting.
• Carbon Market Watch recommends against using error propagation or Monte Carlo analysis for uncertainty, suggesting instead a deduction from total issued credits or using lower-bound estimates of the 95/10 uncertainty analysis.
• While supporting the inclusion of non-permanence risk provisions, the author expresses skepticism toward buffer pools as safeguards, citing inadequate contributions and underestimated risk assessments seen in REDD+ projects.

APA

Carbon Market Watch (n.d.). Carbon Market Watch Submission A6.4-MEP013-A02. https://carbonmarketwatch.org/wp-content/uploads/2026/05/05-2026-AMS-II.G-submission-1.pdf

Chicago

Carbon Market Watch. Carbon Market Watch Submission A6.4-MEP013-A02. n.d. https://carbonmarketwatch.org/wp-content/uploads/2026/05/05-2026-AMS-II.G-submission-1.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch Submission A6.4-MEP013-A02 |url=https://carbonmarketwatch.org/wp-content/uploads/2026/05/05-2026-AMS-II.G-submission-1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch Submission A6.4-MEP013-A02}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2026/05/05-2026-AMS-II.G-submission-1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }