Practitioners Workshop on the "Standards for baseline
scenario identification and baseline emission
calculations"
4-5 March 2011 in Bonn, Germany
March 2011
Gareth Phillips
Chair, Project Developer Forum
Chief Climate Change Officer, Sindicatum Carbon Capital
Overview of presentation
– General comments on “Call for inputs”
– Scope of the tools
– Specific comments on technical aspects of the
draft tools
– Overview of alternative / parallel proposal
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General comments on “Call for Inputs”
– The Call for inputs was entitled “Call for public inputs on the draft "Tool for
baseline scenario identification and baseline emission calculations" but in fact it
covers 3 draft tools
– There is no indication as to the scope of application of these draft tools and
therefore it is very difficult for PPs / stakeholders to comment upon the
content or implications of the tools. If it is made clear how they are to be
applied, a more productive consultation can be undertaken
– The titles are not suitably descriptive, for example the “Draft Tool for
baseline emission calculation” contains important proposals about
benchmarks which stakeholders need to be consulted upon
– The style of presentation and the inconsistencies in the text make the tools
very difficult to comprehend
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Scope of the tools
– The concept of having a single decision making
framework to arrive at the baseline for a project activity is
good in principle
– However, few new meths are being submitted (on
account of the low success rate, long and uncertain time
frames, impending 2012 issues)
– Proposing a radical shake up of the whole approach to
baselines at this time seems inappropriate and out of
touch with reality
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Specific comments on technical aspects
– PDF has concerns about:
• The increase in the volume work required, by all parties, even in simple
cases where baseline determination need not be so complicated
• Reduction in certainty of the outcome with considerable duplication of work
in different PDDs
• Even with the complexity, frequent reference to the “conservative” options
• DOE verification requirements – what third parties would have done
• The arbitrary selection of a 20% threshold for benchmarks, with complete
disregard to practical difficulties of establishing a benchmark and dealing
with heterogeneous technologies
– Assessing the implications of changing to this new approach is a very large
task
– We recommend that before any further work is done, the Secretariat
prepare an impact assessment evaluating the costs and benefits of these
proposals and present it for stakeholder consultation
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Overview of alternative proposals
– PD Forum is very supportive of the concept of Standardized
Baselines
– We believe that new approaches to determining baselines, baseline
emissions and additionality is exactly what the CDM requires
– In our opinion, the proposed tools are simply addressing challenges
with the existing approaches to baselines and additionality and not
addressing the instructions from the CMP to explore new
approaches
– Therefore we disagree with any suggestion that these tools will be
used as a basis to assess methodologies and standardized
baselines
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Alternative / in parallel proposal
– PDF would like to suggest that the Secretariat devote its resources
towards the definition of standardized baselines incorporating the
following proposals:
– As well as recognizing three existing types of methodologies –
AM/ACM; ASM and Micro-scale meths (each with their own
approach to additionality)
– We propose at least 4 more types of methodologies which have
different approaches to the establishment of the baseline and proof
of additionality and will help take the CDM into under represented
countries and sectors:
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Proposed New types of meths
Super Additionality Baseline Boundary Features PoA Activity
Tool areas
Bench- There is no Performance Applies to a A benchmark does not Suitable for EE initiatives,
additionality test benchmark defined population restrict activity to a single PoA approach multiple
marks required for a expressed in t CO2 which has been technology applied to technological
(BM) benchmark because in per unit of activity / used to establish A benchmark requires data other interventions
beating the output. In order to benchmark– from peers – plants of members of
benchmark, the facility motivate action it similar scale, similar scale / technology / the
is acting beyond BAU must be set below technology, social / environmental benchmark
existing environment setting population
performance (i.e.
act to improve
performance) *
Deemed Deemed Savings Assumed rate of Within the Ex ante determination of The CFLs, VFD,
additionality tool** or utilization of geographic scope emission reductions per unit geographic insulation,
savings conventional appliance based on of the DS meth installed with much simpler scope of chillers,
(DS) additionality tool survey data or (national or monitoring requirements*** boundary electric
expert opinion eg 3 regional) suggests PoA vehicles,
hours per CFL not necessary cookstoves
etc.
*REDD falls under BM because national or nested afforestation or deforestation or REDD baselines can be expressed in terms of t CO2 per ha
**Deemed Savings additionality tool (DSAT): to help with establishing additionality for deemed saving projects, it might be possible to define a
DSAT based on a comparison of cost of the proposed technology compared to the discounted cost savings associated with its use
***Could combine multiple technologies with a matrix identifying technologies which interact & a percentage adjustment in DS where appropriate.
SCC Policy Team March 2011 | 8
8
Proposed New types of meths
Super Tool Additionality Baseline Boundary Features PoA Activity
areas
Additional Positive list of types of Qualitatively As defined in the Automated Not required as Household
Technologies technologies / activities defined in meth. applicability criteria additionality test the positive heating and
(AT) that are automatically Quantitatively of the baseline and and baseline additionality status cooking;
additional – for example defined based on additionality determination and quantified biodiesel; off
EE and RE at a literature or local decisions greatly reduce baseline removes grid RE;
household level research data transaction barriers to transport in
burden. scalability least
Well suited to developed
single countries and
technologies sectors
installed in high
numbers
Modeled Benchmark or Modeled using As defined in A theoretical Applicable, and Built
baselines (MB) additionality tool? approved model applicability criteria baseline well suited to environment
design combined of model and constructed on building e.g. building
with industry standards (eg type / the basis of a management energy
standards (e.g. age / size of combination of companies management,
building standards buildings and scope historic data and cities
for HVAC) of building standard) statistically
significant
variables,
achieving a
desired level of
statistical
performance (ie
a high r2)
SCC Policy Team March 2011 | 9
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In conclusion....
– PDF considers that the proposed draft tools may not serve to
enhance the CDM at this point in time
– The overall goal of a unified approach to the establishment of the
baseline has merit, but before any further steps are taken, an impact
assessment should be performed
– The proposed tools will create many challenges and inconsistencies
with existing practice and are likely to substantially distract
resources at a key stage in the CDM’s development
– We believe that the Secretariat’s scarce resources would be better
applied to developing and promoting the concept of standardized
baselines
– We have made some suggestions as to how standardized baselines
could be practically advanced
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