Comment Details
| Comment Author: | Karen Updegraff |
| Organization: | C-Lock Technology, Inc |
| Comment Date: | Thursday, 20 August 2009 |
| Comments: |
Comments specific to Section 4: Real: 4.1, p.16: Ensuring that offsets are not double-counted should not fall under the "real" rubric. That is more of an ex-post check -- for validators or certifiers, part of the serialization process. An emission reduction can be perfectly "real" and still be double-sold. 4.2.1. Quantification 4.2.2. p. 18-19: It is essential that any credible offset quantification standard include an explicit requirement that emission or sequestration estimates be associated with uncertainty bounds at stated confidence levels. No quantification method is entirely free of uncertainty at some stage and this needs to be clearly stated in the quantification report. This type of statistical evaluation is what allows offset credits developed under different projects, systems or standards to be objectively compared. |
| Comments: |
Comments specific to Section 5: Additional: 5.1 (p. 23-4): We would advocate for the adoption of Options C or D: protocol (sector)- specific or hybrid, to allow for the establishment of rigorous but realistic additionality standards that are sensitive to the regulatory, economic and technical context of each project type. At the same time, WCI should beware of developing highly complex and onerous rules as has been done by the CDM, which while adding considerably to the project development burden may also create the possibility of loopholes due to their excessive complexity. 5.2 5.2.1. Baselines. Because baselines are inextricably linked with the determination of additionality, the establishment or modeling of emissions baselines will necessarily follow the policy for additionality. We advocate the following principles with respect to baseline (or business-as-usual, BAU) modeling: - The BAU should be dynamic (not simply a pre-project emission rate). - The BAU should reflect the technical and geographic context of the project, that is, it should be as project-specific as is practicable given the availability of common practice and related emissions data for a sector. In some industrial sectors this may be quite well-specified while in other sectors, such as forestry, it may be necessary to apply broad-regional assumptions. The use of integrated modeling approaches may allow quite sophisticated projections of BAU scenarios. - It would simplify the development of new methodologies if WCI provides a set of default BAU methodologies, which methodology developers can opt to use or reference in lieu of defining a project-specific BAU methodology. Moreover, standardized BAU approaches will facilitate and expedite the verification process. 5.2.3. Crediting period (p.28): We agree that allowing additionality to be voided before the end of a crediting period may serve as a disincentive to the early adoption of mitigation technologies that might, in future, be required. Additionality reviews should employ a consistent set of criteria throughout each crediting period. However, it may be expedient to apply short crediting periods in sectors where technology is evolving rapidly, with frequent renewals to allow for BAU re-evaluation. 5.3. Implementation (p.31). While the 5 basic additionality criteria as laid out by the CDM appear straighforward in fact their application across sectors is fraught with difficulties. Any attempt to apply national-scale "standardized .." additionality assessment tools is probably doomed from the start. Additionality must ultimately be determined in a regional if not local and sector-specific context. It may be more productive to set out a basic assessment framework and provide guidelines regarding how it may be legitimately modified to fit local conditions. |
| Comments: |
Comments specific to Section 7: Verifiable: 7.1. Policy considerations (p. 36). We support the use of disinterested 3rd party verifiers, who are subjected to conflict-of-interest assurances for each project that they undertake. The use of national accreditation criteria would confer additional credibility on the process. 7.2. Supporting principles 7.2.1. Validation (p.38). Combining validation with the initial project review seems risky, particularly if it is performed by the same technical service providers who may be conducting the quantification; at minimum some level of ex post auditing of project parameters and predicted results would be necessary. 7.2.2. Enforcement. 7.2.3. Materiality. (5% threshold; propagation of metering errors not required.) 7.3. Implementation (p.40). Self-certification is an invitation to gaming of the system and ultimately a false savings. It will not promote confidence in the offset system. |
| Comments: |
Comments specific to Section 8: Other considerations: 8.1. Transparency (p.41). An additional component of transparency is the publication of all methodologies, and the use of well-documented and auditable quantification algorithms and models by accredited technical service providers. |
| Comments: |
Please provide any additional/general feedback. : General comments: The criteria say nothing about geographic provenance: will offset projects be accepted only within the WCI area, anywhere in N. America, or anywhere in the world? Will there be discounting of international offsets |