The Integration of PoA and NAMA; how can
one support the other
Ingo Puhl
South Pole Carbon Asset Management Ltd.
Bonn, 8. May 2011
Prepared by South Pole on the basis of
analysis conducted for:
PoA Support Center
The Big Picture: CDM projects and programs will be
nested within NAMA frameworks
• Principal Observations
–
NAMA MRV, i.e.
IPCC 2006
NAMA
target
GHG
PoA baseline
emissions
PoA CPA
emissions
A NAMA creates a voluntary
emissions target in a developing
country on sector or sub-sector level.
– The environmental integrity of a
NAMA target (MRV, enforcement) is
managed on the NAMA level by a
national authority.
– PoA baseline emissions are either a)
already coherent with NAMA target
trajectory (on aggregate) or b) a
share of CER is used for domestic
compliance.
• Implications
–
CDM-style
MRV
A NAMA framework that surrounds a
PoA facilitates the simplification of
CDM/PoA design because
environmental integrity is controlled
on NAMA level.
– Existing CDM/PoA “building blocks”
can be used on NAMA level for
NAMA design
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Pre-Conditions for PoA Simplification;
Analogy to Joint Implementation track 1 & 2
Parameter
JI
NAMA
Country Eligibility
Party to KP
Party to KP and has submitted NAMA with
UNFCCC
Target
Has calculated and recorded
its assigned amount units.
Has determined baseline, target and recorded
NAMA.
MRV system
Has in place a national
system for estimating of GHG
emissions in compliance with
international rules.
Has established NAMA MRV system
Register
Has in place a national
register in compliance with
international rules
Has in place NAMA register in compliance with
international rules
Annual inventory
submission
Has submitted annually most
recent required inventory in
common reporting format
Has submitted latest NAMA inventory
Supplementary
info
Has submitted supp. Info on
assigned amount units
plus/minus issued ERU
Has submitted supp/info required to calculate
NAMA baseline and target emissions, issued
CER from “nested” activities
Minimum requirement for JI track 2
Additional requirements for JI track 1
PoA that are located “under a cap” should benefit from
simplification, in analogy to JI procedures
• Streamlined Registration and Inclusion Process
• Determination of eligibility, monitoring & verification subject to national rules
and procedures (track 1 only) OR streamlined determination & verification
process involving an AIE (DOE) and two JISC members advised by experts.
• Streamlined Process to Determine Baseline and Additionality
• Choose an appropriate method using traceable and transparent information
showing that the project will lead to reductions of GHG emissions below
baseline.
• MRV
• Appropriate monitoring plan, allowing combinations of CDM methods.
• Defined materiality thresholds
PoA Building Blocks for Good NAMA Design:
How can the NAMA concept benefit from PoA experience?
PoA Design
Element
Applicable for NAMA
Technical criteria that provide an “objective” basis to assess eligibility
of a facility or activity (type of facility, unit sizes, type of intervention ..)
Baseline Setting
Standardized elements that have been developed for CDM
methodologies::
 large-scale benchmarks (carbon intensity of power grid, national or
regional NRB usage rates)
 deemed savings (Nepal: average per household biomass use)
 status-quo baselines:
 modelled baselines
PoA Elements
Eligibility Criteria
can be used to determine NAMA baselines and targets.
MRV
A number of CDM MRV procedures are directly applicable :
• deemed savings approach
• methods that focus on large emission sources with simple MRV
requirements that facilitate cost-effective MRV on facility level
Implementation
and Operation
Some CME already operate at NAMA scale and is also an integral
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part of existing support mechanisms.
Benefits of PoA – NAMA Integration
• Procedural Simplification in PoA design and registration
•
PoA/CPA additionality is derived from the NAMA and using procedures
controlled by the host country with a strong link to its domestic policy.
• PoA can develop baseline derived from NAMA target (close to benchmark
approach)
• Existing mechanism to implement “credited” NAMA instead of new
mechanism
•
NAMA could be operated mainly through (one or more) policy-driven PoA in
conjunction with ODA-style capacity building/support interventions.
• Surplus ER (outside of PoA) could be transacted through bilateral output-based
assistance approach (OBA).
• Shifting responsibility for the protection of environmental integrity to host
country Parties, de-centralize the role of CDM EB
•
•
The Party in control of NAMA compliance ensures environmental integrity on
system level; typical CDM EB concerns over PoA level environmental integrity
become less relevant..
I.e. DOE liability for wrongful inclusion can be addressed through NAMA
eligibility criteria.
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Recommendations/Next Steps
• Explore the feasibility and benefits of this approach for an increasing
number of case-studies
•
•
CDM method usability vary widely depending on the underlying activity.
Availability of substantial benefits need to be properly understood by Parties.
• Integrate the PoA/CDM reform process agenda with NAMA negotiations to
facilitate integration
•
Define requirements for the design of NAMA-level estimation methods for GHG
emission inventories (based on national GHG inventory guidelines).
•
Define requirements for the formulation of NAMA targets comparable to
“assigned amount units”.
• Prepare CDM EB guidance on determination of additionality for
projects/programs that are nested in eligible NAMA frameworks; in accordance
with JI-style procedures on additionality for JI (track 1 and 2).
• Prepare CDM EB guidance on MRV flexibility on the activity level in accordance
with JI-style procedures on MRV procedures (track 1 and 2).
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