Search Climate Insights Directory

A coalition of 109 civil society organisations calls for a second commitment period of the Kyoto Protocol and the closure of carbon market loopholes. The letter demands that market-based mechanisms be tied to binding targets and proposes specific reforms to the Clean Development Mechanism (CDM), including human rights safeguards, a robust appeals procedure, and the exclusion of non-additional projects and Carbon Capture and Storage (CCS).

The CDM Executive Board's 64th meeting addressed the establishment of a high-level policy dialogue to review CDM experience for the post-2012 period and considered a 'risk-based-approach' to manage a surge in project registrations. Key discussions included proposals to tighten additionality testing for large-scale projects, the development of new transparency standards (PS, VVS, and PCP), and the establishment of liability rules for excess Certified Emission Reduction (CER) issuance resulting from fraud or negligence.

The Sierra Club CDM Watch requests that the CDM Executive Board reject the registration of the Guangdong Pinghai Power Plant in China. The authors argue the project is non-additional because it was operational before validation, ultra-supercritical coal technology is already common practice in China, and the project's financial analysis is flawed, failing to consider alternative tariff structures or realistic coal price fluctuations.

The document asserts that coal projects in the Clean Development Mechanism (CDM) are non-additional, conflict with sustainability goals by harming local ecosystems, and lock in long-term CO2 emissions. It further claims that flawed CDM rules lead to significant over-crediting of these projects, which are often used merely as an additional revenue stream for planned investments.

Sierra Club CDM Watch requests the CDM Executive Board to reject the registration of Project 4807, asserting that the use of supercritical technology was mandated by the Punjab State Electricity Board and is already the industry standard in India. The authors claim the project is not additional because financing was secured independently of CDM support and that the Validation Report used manipulated cost estimates and an inappropriate baseline to justify the project's economic viability.

Sierra Club and CDM Watch object to the CDM Secretariat's decision to disregard a June 2011 letter requesting a review of the additionality of CDM Project 4533 (Coastal Andhra Power Ltd., India). The authors argue that the Secretariat's failure to forward the letter to the CDM Executive Board before the July 3 deadline—based on a minor project number error—undermines the CDM's credibility and transparency. They highlight that the project is high-risk, seeking over 12 million CERs while generating 215 million tons of CO2 emissions, and call for clarified guidelines on stakeholder engagement and the forwarding of public concerns.

Sierra Club CDM Watch submitted a letter to the CDM Executive Board arguing that Project 4629 in India is non-additional. The authors contend that the project would proceed regardless of CDM support because the Government of India mandates supercritical technology and the owner, Reliance Power, has already committed to such technology through a US$10 billion order. They further argue that the project's baseline scenario is flawed, fails to consider energy efficiency alternatives, and uses an unrealistically narrow coal price sensitivity analysis. If registered, the project could receive over 21 million CERs, potentially providing a windfall of approximately €257 million.

A formal request by Sierra Club and CDM Watch to the CDM Executive Board to review the additionality of Project 4533 in India. The authors argue that the project does not meet CDM rules because the Government of India mandated supercritical technology, financing was already secured, and the project sponsor's own shareholder communications describe CDM credits as a 'new revenue stream' rather than a necessity for implementation. They further contend that the project's baseline assumptions regarding coal prices are unrealistically low and that alternative energy efficiency scenarios were ignored.

Carbon Market Watch requests that the CDM Executive Board define who can submit methodology revisions and clarifications, arguing that allowing all stakeholders—not just project participants—is essential for the integrity of the Clean Development Mechanism.

NGOs express concern over a European Commission draft proposal that would treat all information in the EU ETS Union Registry, including account holdings and serial numbers, as confidential. The briefing argues that removing serial numbers would eliminate the traceability necessary to enforce the ban on industrial gas (HFC and N2O) carbon credits and verify the eligibility of Kyoto units based on issuance dates. The authors urge EU Member States to maintain open access to installation and account data to ensure market accountability and the effective implementation of the scheme.

CDM Watch opposes the validation of the Thoothukudi Thermal Power Project in India, asserting that the project is not additional and would lead to the issuance of Certified Emissions Reductions (CERs) that do not represent actual emissions reductions.

Carbon Market Watch and partner organizations urge ERM Certification and Verification Services Ltd not to validate the Sujiahekou Hydropower Station, alleging that the project owner failed to consider the CDM before construction, may have provided untruthful information, and may lack required legal approval from China's National Development and Reform Committee (NDRC).

The statement outlines requirements for a fair appeals process for CDM Executive Board decisions, emphasizing the need for an independent appeals body, broad legal standing for civil society organizations, and the ability to challenge both procedural and substantive violations.

CDM Watch recommends several procedural improvements to the CDM Executive Board to enhance accessibility and communication for civil society, including better notification systems, language translation of project documents, and extended public commenting periods.

CDM Watch and partner organizations are calling on EU Environment Ministers to ensure that HFC-23 and adipic acid (N2O AA) offset credits are banned from national registries for non-traded sectors by April 2013. While these credits are banned from the EU Emissions Trading System (EU ETS) as of 30 April 2013, the authors argue that the Effort Sharing Decision (ESD) could be exploited to allow their use toward national targets, undermining domestic emissions reductions and the Montreal Protocol.

The submission argues that the Clean Development Mechanism (CDM) has already failed its primary objectives and that carbon capture and storage (CCS) is unlikely to meet the specific requirements of this offset framework, making its inclusion inappropriate.

The report examines the consistency of grid emission factors (grid EFs) published by host country DNAs with CDM rules. It finds that most DNAs provide insufficient data for external verification and identifies overestimations of grid EFs and coal benchmarks in China and India. Specifically, it notes inconsistent sampling in China and the omission of non-CDM renewable plants in India's build margin calculations. The study estimates that these deficiencies led to an over-crediting of 11 million pre-2012 CERs for electricity-related projects in these two countries, representing approximately 2.5% of their total CER volume.

A coalition of environmental and human rights organizations is challenging the registration of the Barro Blanco Hydroelectric Project (PA #3237) in Western Panama. The groups argue that the project's additionality is questionable and raise serious concerns regarding the lack of public consultation, the potential misuse of Certified Emission Reductions (CERs) for community compensation, and human rights abuses by GENISA against the Ngobe indigenous peoples.

CDM Watch argues that HFC-23 and N2O abatement projects under the Clean Development Mechanism (CDM) create perverse incentives and fail to represent real emission reductions. The organization calls on EU Member States to support a European Commission draft Regulation that bans the use of these credits in the EU ETS from 1 January 2013 and prohibits their banking into Phase 3 to maintain environmental integrity over private investor interests.

Biofuel Watch, Salva la Selva/Rettet den Regenwald, and CDM Watch have challenged the proposed CDM project 3197 in Bajo Aguan, Honduras. The organizations argue that the project fails to meet 'sustainable development' and additionality requirements due to the project developer's alleged human rights abuses and disputed land claims.