Additionality Emissions One of the difficulties of the CDM is in judging whether or not projects truly make additional savings in GHG emissions (Carbon Trust, 2009, p. 54-56).
Types Additionality is much contested. There are many rival interpretations of additionality: • What is often labelled 'environmental additionality' has that a project is additional if the emissions from the project are lower than the baseline. It generally looks at what would have happened without the project. • Another interpretation, sometimes termed 'project additionality', the project must not have happened without the CDM. A number of terms for different kinds of additionality have been discussed, leading to some confusion, particularly over the terms 'financial additionality' and 'investment additionality' which are sometimes used as synonyms. 'Investment additionality', however, was a concept discussed and ultimately rejected during negotiation of the Marrakech Accords. Investment additionality carried the idea that any project that surpasses a certain risk-adjusted profitability threshold would automatically be deemed non-additional. 'Financial additionality' is often defined as an economically non-viable project becoming viable as a direct result of CDM revenues. Many investors argue that the environmental additionality interpretation would make the CDM simpler. Environmental NGOs have argued that this interpretation would open the CDM to free-riders, permitting developed countries to emit more CO2e, while failing to produce emission reductions in the CDM host countries. Gillenwater (2011) evaluated the various definitions of
additionality used within the CDM community and provided a synthesis definition that rejects the notion of there being different types of additionality. Schneider (2007) produced a report on the CDM for the WWF. set by the CDM Executive Board for assessing additionality.
Views on additionality An argument against additionality is based on the fact that developing countries are not subject to emission caps in the Kyoto Protocol (Müller, 2009, pp.
iv, 9-10). On these basis, "business-as-usual" (BAU) emissions (i.e., emissions that would occur without any efforts to reduce them) in developing countries should be allowed. By setting a BAU baseline, this can be interpreted as being a target for developing countries. Thus, it is, in effect, a restriction on their right to emit without a cap. This can be used as an argument against having additionality, in the sense that non-additional (i.e., emission reductions that would have taken place under BAU) emission reductions should be credited. Müller (2009) argued that compromise was necessary between having additionality and not having it. In his view, additionality should sometimes be used, but other times, it should not. According to World Bank (n.d., pp. 16–17), additionality is crucial in maintaining the environmental integrity of the carbon market. To maintain this integrity, it was suggested that projects meeting or exceeding ambitious policy objectives or technical standards could be deemed additional.
Concerns Overall efficiency Pioneering research has suggested that an average of approximately 30% of the money spent on the open market buying CDM credits goes directly to project operating and capital expenditure costs. Other significant costs include the broker's premium (about 30%, understood to represent the risk of a project not delivering) and the project shareholders' dividend (another 30%). The researchers noted that the sample of projects studied was small, the range of figures was wide and that their methodology of estimating values slightly overstated the average broker's premium.
The risk of fraud One of the main problems concerning CDM-projects is the risk of fraud. The most common practices are covering up the fact that the projects are
financially viable by themselves and that the
emission reductions acquired through the CDM-project are not
additional. Exaggerating the carbon benefits is also a common practice, just as
carbon leakage. Sometimes a company even produces more to receive more
CERs. Most of the doubtful projects are
Industrial gas projects. Even though only 1.7% of all CDM-projects can be qualified as such, extraordinarily they account for half to 69% of all CERs that have been issued, contributing to a collapse in the global market for all CERs. In this way, the CDM has become a stimulus for
carbon leakage, or even to simply produce more.
Hydro-projects are also quite problematic. Barbara Haye calculated that more than a third of all hydro-projects recognized as a CDM-project "were already completed at the time of registration and almost all were already under construction", which means that CERs are issued for projects that are not additional, which again indirectly leads to higher emissions. Moreover, most of the proposed carbon benefits of these projects are exaggerated. It seems clear that the CDM is not governed according to the rules of '
good governance'. Solving this problem might require a genuine democratization in the election of the EB-members and thus a shift in thinking from government to
governance. In practice this would mean that all the
stakeholders should get a voice in who can have a seat in the EB. Another important factor in the dysfunctionality of the EB is the lack of time, staff and financial resources it has to fully evaluate a project proposal. This indicates that implementation is the place where the shoe pinches, as usually happens in environmental issues (mostly due to a lack of funds). There have been indications in recent years that the EB is becoming more strict in its decisions, due to the huge criticism and the board getting more experience. However, carbon emissions from deforestation represent 18-25% of all emissions, and will account for more carbon emissions in the next five years than all emissions from all aircraft since the Wright Brothers until at least 2025. This means that there have been growing calls for the inclusion of forests in CDM schemes for the second commitment period from a variety of sectors, under the leadership of the
Coalition for Rainforest Nations, and brought together under the
Forests Now Declaration, which has been signed by over 300 NGOs, business leaders, and policy makers. There is so far no international agreement about whether projects avoiding deforestation or conserving forests should be initiated through separate policies and measures or stimulated through the carbon market. One major concern is the enormous monitoring effort needed to make sure projects are indeed leading to increased carbon storage. There is also local opposition. For example, 2 May 2008, at the United Nations Permanent Forum on Indigenous Issues (
UNPFII), Indigenous leaders from around the world protested against the
Clean Energy Mechanisms, especially against
Reducing emissions from deforestation and forest degradation.
Reasons for including avoided deforestation projects in the CDM Combating global warming has broadly two components: decreasing the release of greenhouse gases and sequestering greenhouse gases from the atmosphere. Greenhouse gas emitters, such as coal-fired power plants, are known as "sources", and places where carbon and other greenhouse gases, such as methane, can be sequestered, i.e. kept out of the atmosphere, are known as "sinks". The world's forests, particularly rain forests, are important carbon sinks, both because of their uptake of CO2 through photosynthesis and because of the amount of carbon stored in their woody biomass and the soil. When rain forests are logged and burned, not only do we lose the forests' capacity to take up CO2 from the atmosphere, but also the carbon stored in that biomass and soil is released into the atmosphere through release of roots from the soil and the burning of the woody plant matter. An emerging proposal, Reduced Emissions from Avoided Deforestation and Degradation (REDD), would allow rain forest preservation to qualify for CDM project status.
REDD has gained support through recent meetings of the COP, and will be examined at Copenhagen.
Coal thermal power generation in India and China In July 2011, Reuters reported that a 4,000 MW coal thermal electricity generation plant in Krishnapatnam in Andhra Pradesh had been registered with the CDM. CDM Watch and the Sierra Club criticised the plant's registration and its eligibility for certified emission reduction units as clearly not additional. A CDM spokesperson dismissed these claims. According to information provided to Reuters, there are total of five coal-fired electricity plants registered with the CDM, four in India with a capacity of 10,640 MW and one 2,000 MW plant in China. The five plants are eligible to receive 68.2 million CERs over a 10-year period with an estimated value of 661 million euros ($919 million) at a CER price of 9.70 euros.
Industrial gas projects Some CERs are produced from CDM projects at refrigerant-producing factories in non-Annex I countries that generate the powerful greenhouse gas HFC 23 as a by-product. These projects dominated the CDM's early growth, and are expected to generate 20% of all credited emission reductions by 2012 (Carbon Trust, 2009, p. 60). As of 21 July 2008, CERs from hydropower projects are not listed on European carbon exchanges, because different member states interpret these limitations differently. Organisation seeking to measure the degree of compliance of individual projects with WCD principles can use the
Hydropower Sustainability Assessment Protocol, recommended as the most practical currently available evaluation tool.
NGOs and researchers have criticized the inclusion of large
hydropower projects, which they consider unsustainable, as CDM projects. As of 2014, the largest power plant to receive CDM support was the
Jirau Hydroelectric Plant in Brazil.
Other concerns Renewable energy In the initial phase of the CDM, policy makers and NGOs were concerned about the lack of renewable energy CDM projects. As the new CDM projects are now predominantly renewables and energy efficiency projects, this is now less of an issue.
Sinks Some NGOs and governments have raised concerns about the inclusion of
carbon sinks as CDM projects. The main reasons were fear of oversupply, that such projects cannot guarantee permanent storage of carbon, and that the methods of accounting for carbon storage in biomass are complex and still under development. Consequently, two separate carbon currencies (temporary CERs and long-term CERs) were created for such projects.
Windfarms in Western Sahara In 2012, it was announced that a windfarm complex is going to be located near
Laayoune, the capital city of the disputed territory of Western Sahara. Since this project is to be established under tight collaboration between the UN (which itself recognizes Western Sahara's status of a non-autonomous country) and the Moroccan government, it has been questioned by many parties supporting Western Sahara independence, including the
Polisario.
Suggestions In response to concerns of unsustainable projects or spurious credits, the
World Wide Fund for Nature and other NGOs devised a 'Gold Standard' methodology to certify projects that uses much stricter criteria than required, such as allowing only renewable energy projects. For example, a
South African brick kiln was faced with a business decision; replace its depleted energy supply with coal from a new
mine, or build a difficult but cleaner
natural gas pipeline to another country. They chose to build the pipeline with
SASOL. SASOL claimed the difference in GHG emissions as a CDM credit, comparing emissions from the pipeline to the contemplated coal mine. During its approval process, the validators noted that changing the supply from coal to gas met the CDM's 'additionality' criteria and was the least cost-effective option. However, there were unofficial reports that the fuel change was going to take place anyway, although this was later denied by the company's press office.
Successes Schneider (2007, p. 73) commented on the success of the CDM in reducing emissions from industrial plants and landfills. Schneider (2007) concluded by stating that if concerns over the CDM are properly addressed, it would continue to be an "important instrument in the fight against climate change." ==See also==