CDM-EB77-A12-CLAR

Clarification

Validation of post-registration changes and verification by the same DOE for the same project activity or programme of activities

Version 01.0

1. Introduction

1. At its seventy-seventh meeting, the Executive Board of the clean development mechanism (CDM) (hereinafter referred to as the Board) considered the issue of whether the current CDM rules and regulations allow for the same designated operational entity (DOE) to conduct the assessment of post-registration changes and verification for the same registered CDM project activity or programme of activities (PoA) if the request for the post-registration changes is submitted prior to the submission of the request for issuance in accordance with paragraph 134 of the “Clean development mechanism project cycle procedure” (PCP) (version 05.0) (CDM-EB65-A32-PROC).

2. Paragraph 27(e) of the CDM modalities and procedures (decision 3/CMP.1, annex) states that “A designated operational entity shall: … (e) perform one of the following functions relating to a given CDM project activity: validation or verification and certification. Upon request, the Executive Board may, however, allow a single designated operational entity to perform all these functions within a single CDM project activity”. Based on this, paragraphs 208 and 297 of the “Clean development mechanism validation and verification standard” (VVS) (version 05.0) (CDM‑EB65‑A04‑STAN) prohibit the same DOE from performing both validation and verification for the same project activity (unless it is a small-scale project activity) or PoA unless the Board grants an exception.

3. With regard to the DOE’s assessment of post-registration changes, existing provisions, including paragraph 211 of the “Clean development mechanism project standard” (PS) (version 05.0) (CDM-EB65-A05-STAN), paragraph 247 of the VVS and paragraph 134(b) of the PCP, indicate that it is a validation activity.

4. However, in accordance with paragraph 136 of the PCP and paragraph 249(a) of the VVS, the DOE that performs a verification is allowed to submit a request for post-registration changes as part of the request for issuance, provided that the post-registration changes do not require prior approval by the Board in accordance with the PS.

5. Also, paragraph 134(a) of the PCP and paragraph 249(b) of the VVS could imply that the same DOE may perform both a validation of post-registration changes and a verification for the same project activity or PoA if the need for prior approval by the Board of the post-registration changes is determined by the DOE when performing the verification.

6. On the other hand, it is not clear whether the same DOE may also perform both a validation of post-registration changes and a verification for the same project activity or PoA if the project participants or the coordinating/managing entity have requested a DOE, at any time prior to the commencement of a verification, to perform a validation of post-registration changes in accordance with paragraph 134(b) of the PCP and paragraph 250 of the VVS.

2. Clarification

7. The Board agreed to clarify that for the two cases referred to in paragraph 134 of the PCP, which correspond to the cases referred to in paragraphs 249(b) and 250 of the VVS, the same DOE may perform a validation of post-registration changes and a verification for the same project activity or PoA.

- - - - -

Document information