Date:2024/01/09 12:26:24
Column:Validation and Verification on GHG Emission Reductions
Validation
1. Purpose and scope
To ensure that CEC conducts thorough and independent assessment of a proposed CDM PA or PoA/CPA submitted for requesting for registration as per the applicable CDM rules and requirements, effectively implement and complete validation activities, hereby this procedure is established.
This procedure stipulates the responsibilities, process flow and requirements for CEC validation activities.
2. Reference
CDM Accreditation Standard v7.0
CDM validation and verification standard for project activities v3.0
CDM validation and verification standard for programmes of activities v3.0
CDM project standard for project activities v3.0
CDM project standard for programmes of activities v3.0
CDM project cycle procedure for project activities v3.0
CDM project cycle procedure for programmes of activities v3.0
3. Responsibilities
3.1 PI Division is responsible for the selection of the validation team, and the preparation and implementation of validation;
3.2 The appointed validation team shall implement and complete the validation task, and compile draft/final validation report;
3.3 QA Division is responsible for organizing the technical reviews of the draft final validation report, after technical reviewing, QA division is responsible for the completeness check of the final validation report;
3.4 CI Division is responsible for the necessary communication with the PPs or CMEs;
3.5 CDM Director is responsible for verifying the final validation report;
3.6 CDM Quality Manager is responsible to make the final decision of validation opinion;
3.7 General Manager is responsible to approve and issue the final decision on validation opinion and the final validation report.
4. Validation principles
4.1 Validation requirements
The following principles guide the preparation, execution, and reporting of CEC validation activities.
(1) Independence Remain independent of the activity being validated, and free from bias and conflict of interest. Maintain objectivity throughout the validation to ensure that the findings and conclusions will be based on objective evidence generated during the validation.
(2) Ethical conduct Demonstrate ethical conduct through trust, integrity, confidentiality and discretion throughout the validation process.
(3) Fair presentation Reflect truthfully and accurately validation activities, findings, conclusions and reports. Report significant obstacles encountered during the validation process, as well as unresolved, diverging opinions among validators, the responsible party (e.g. the secretariat/ EB) and the client (e.g. project participants).
(4) Due professional care Exercise due professional care and judgment in accordance with the importance of the task performed and the confidence placed by clients and intended users. Have the necessary skills and competences to undertake the validation.
Prior authorization notes before validation:
For the validation of renewal of crediting period of CDM PA, if CEC has performed verification for the registered CDM PA, CEC shall not perform the validation for renewal of crediting period for the same registered CDM PA, unless the CDM PA is a registered small-scale CDM project activity or a registered small-scale A/R CDM project activity or CEC is authorized by the Board to do so in accordance with the “CDM project cycle procedure for project activities”. Adequate justification shall be demonstrated for the authorization.
For the validation of renewal of PoA period, if CEC has performed verification for the registered CDM PoA, CEC shall not perform this validation for the same registered CDM PoA, unless CEC is authorized by the Board to do so in accordance with the “CDM project cycle procedure for programmes of activities”. Adequate justification shall be demonstrated for the authorization.
For the validation of renewal of crediting period of a CPA, if CEC has performed verification for the same CPA, CEC shall not perform this validation for the same CPA unless CEC is authorized by the Board to do so in accordance with the “CDM project cycle procedure for programmes of activities”. Adequate justification shall be demonstrated for the authorization.
4.2 General validation approach
In carrying out its validation work, CEC shall (1) Determine whether the proposed PA or PoA comply with the requirements of paragraph 37 of the CDM M&Ps, the applicability conditions of the selected methodology, and where applicable, the selected standardized baseline, and guidance issued by EB; (2) Assess the claims and assumptions made in the PA-PDD or PoA-DD. The evidence used in this assessment shall not be limited to that provided by the project participants or CME.
General validation approach is listed for validation activities below:
(a) Apply the most recent applicable decisions and guidance provided by the Board.
(b)1 Determine whether each CDM PA meets all applicable CDM rules and requirements, including those specified in the “CDM project standard for project activities”, relevant methodologies, tools and standardized baselines.
(b)2 Determine whether each CDM PoA or CPA meets all applicable CDM rules and requirements, including those specified in the “CDM project standard for programmes of activities”, relevant methodologies, tools and standardized baselines.
(c)Assess the accuracy, conservativeness, relevance, completeness, consistency and transparency of the information provided by the project participants.
(d)Determine whether information provided by the project participants or CME is reliable and credible.
(e)Apply consistent validation criteria:
(i)To the requirements of the applicable approved methodologies and, where applicable, the applicable approved standardized baselines throughout the crediting period(s);
(ii)To CDM PAs or PoAs with similar characteristics such as a similar application of the applicable approved methodologies, approved standardized baselines, use of technology, time period or region;
(iii)To expert judgments, over time and among CDM PAs or CDM PoAs/CPAs;
(f)Base its findings and conclusions on objective evidence and conduct all validation activities in accordance with CDM rules and procedures.
(g)Not omit evidence that is likely to alter the validation opinion.
(h)Present information in the validation report in a factual, neutral and coherent manner and document all assumptions, provide references to background material, and identify changes made to the documentation.
(i)Safeguard the confidentiality of all information obtained or created during the validation.
(j)Use of and compliance with applicable standards.
(k)Use of applicable forms.
(l)Use of applicable global warming potentials.
When implementing the validation, CEC applies standard auditing techniques to assess the information provided by the project participants or the CME, including, but not limited to:
(a)Document review, involving:
(i)A review of data and information;
(ii)Cross checks between information provided in the PA-PDD or PoA-DD/CPA-DD and information from sources other than those used, if available, the CEC’s sectoral or local expertise and, if necessary, independent background investigations;
(b)Follow-up actions (e.g. on-site inspection/ telephone or e-mail interviews), including:
(i)Interviews with relevant stakeholders in the host country, personnel with knowledge of the project design and implementation;
(ii)Cross checks between information provided by interviewed personnel (i.e. by checking sources or other interviews) to ensure that no relevant information has been omitted;
(c)Reference to available information relating to projects or technologies similar to the proposed CDM project activity or PoA/CPA under validation;
(d)Review, based on the selected methodology and, where applicable, the selected standardized baseline, of the appropriateness of formulae and accuracy of calculations;
(e)Sampling approach in accordance with the “Standard for sampling and surveys for CDM project activities and PoA”, including:
(i)A random sampling for cases where the project participants or the CME did not apply a sampling approach;
(ii)An acceptance sampling or another sampling approach for cases where the project participants or the CME applied a sampling approach.
4.3 Validation process
The procedure for validation implementation is initiated after the contract signed. The validation team should, as per related requirements, complete all aspects of validation task within the regulated period.
Chart 1: CDM PA and PoA validation process
5. Management requirements
5.1 Selection of validation team
PI Division is responsible for planning the implementation arrangement of the CDM PA or PoA/CPA validation and appointing the presupposed validation team and final validation team, following the specific requirements of Procedure for selection and allocation of team for VV functions（CEC-3012C）.
5.2 Validation task arrangement
The validation team leader has overall responsibility for the implementation of the validation of the proposed PA or PoA/CPA. According to the requirements of VVS(including VVS-PA and VVS-PoA) and the commitment on relevant service in CDM Service Contact, the validation team leader should manage all aspects of validation task undertaken within the regulated period, including:
(1)Making the Validation Plan (time, location, assessment principle, task allocation among validation team members and validation content etc.);
(2)Planning and making effective use of human resources and managing validation teams;
(3)Planning and organizing work effectively and performing it within the agreed time schedule, to prioritize and focus on matters of significance;
(4)Representing the validation team in communications with the clients;
(5)Preventing and resolving conflicts;
(6)Managing the validation process and concluding the decisions affecting the validation process;
(7)Taking charge of drafting the validation report and the subsequent requests of possible corrective/clarification action;
(8)Leading the team to reach conclusions on all aspects of validation and complete the validation report.
Team members should assist the team leader to accomplish the validation task as assigned, and should be familiar with project documents and other validation preparation documents related to their own assignment.
5.3 PA-DD or PoA-DD publicity
After received the PA-DD or PoA-DD provided by client, the validation team shall start the procedure for global stakeholder process. CI Division shall upload PDD or PoA-DD onto the UNFCCC website for publicity for global stakeholder consultation.
During the validation process, the validation team needs to consider the comments received from publicity, and the validation report is required to contain concrete measures taken in response to the received comments during the validation. If the views or opinions have not been adequately demonstrated or the project activity is not in conformance to CDM requirements, the validation team shall require PP/CME to further clarify these opinions.
The validation team shall determine whether authentic and relevant comments in the global stakeholder consultation were taken into due account in the PDD of the proposed CDM PA or PoA-DD of the proposed CDM PoA.
5.4 Document review
At the same time of global stakeholder consultation process, the validation team reviews the project documents. Through document review, it is confirmed that the description on proposed CDM PA in the PDD or PoA/CPA in the PoA-DD/CPA-DD fully include all relevant content and it is accurate;
Document review, including:
(1)Check the applied valid version of standards, methodological tools and guidelines, applicable forms, applicable global warming potentials and other relevant provisions;
(2)Review data and information, to verify the correction, the credibility and interpretability of the information provided;
(3)Multi-check the information of the PA-DD or PoA-DD/CPA-DD and other sources (if applicable), if necessary, to conduct an independent document review.
5.5 Background investigation
If necessary, the background investigation should adopt a risk-based validation principle, thus the validation should be focused on the content of the risk affecting the successful implementation and accomplishment of the project. For example: Project technology, environmental protection legislation and regulation of the host country, the approval letters on the project from the governments of the host country and the developed country in previous period, memorandum of understanding and non-objection letter, sustainable priorities in the host country, the whole economic tendency and policies of the host country, etc.
5.6 Follow up actions: on-site inspection
5.6.1 On-site visit
During the process of collecting comments from stakeholders, the validation team can consider the implementation of follow up on-site inspection according to the nature and progress of project activities.
Each validation for request for registration of CDM-PA, on-site inspection is mandated for the followings:
(a)Its estimated annual average of greenhouse gas (GHG) emission reductions or net anthropogenic GHG removals is more than 100,000 t CO2 eq;
(b)or There is pre-project information that is relevant to the requirements for registration of the project activity and may not be traceable after the registration.
For CDM-PA cases that are not referred to in paragraph above, it is optional for CEC to conduct an on-site inspection at validation. If CEC does not conduct an on-site inspection as a means of validation, the validation report shall describe the alternative means to identify the risks emanating from not conducting mandatory site visit and justify that they are sufficient for the purpose of validation. Basically the alternative means to confirm the PAs situation includes but not limited telephone or e-mail review, virtual meeting, document review, check the official website of the projects, check other public information etc.
According to VVS-PoA, it is optional for CEC to conduct an on-site inspection for validation for the registration of a PoA, renewal of PoA period, or post-registration changes of a registered PoA. If CEC conducts an on-site inspection, it does not necessarily need to include the visit to the geographical locations where CPAs will be or are implemented, but could be to the office of the coordinating/managing entity. If CEC does not conduct an on-site inspection as a means of validation, CEC shall describe in the validation report the alternative means to identify the risks emanating from not conducting mandatory site visit and justify that they are sufficient for the purpose of validation. Basically the alternative means to confirm the PAs situation includes but not limited telephone or e-mail review, virtual meeting, document review, check the official website of the projects, check other public information etc.
For the validation visit to the PA or PoA site, the following personnel, at minimum, shall participate in the visit:
(1)The team leader;(in case of site visit to multiple sites, the team leader is required to visit one or more sites, as appropriate);
(2)The team member(s) qualified in the technical area(s) of the CDM PA or PoA being validated.
The main contents of on-site inspection include:
(1)Interviewing the host country stakeholders, as well as the people familiar with the project design and implementation;
(2)Multi-checking the information provided by respondents (i.e., to verify the information sources or verify other accesses) to ensure that related information is not omitted during validation.
5.6.2 Remote validation when no mandatory site visit under force majeure conditions
According to CDM-EB113-A07
If the site visits cannot be postponed, CEC shall justify in the validation report that why the site visits cannot be postponed, including the demonstration of a significant impact of delaying the site visits on CEC/PP/CME. The justification could include commitment/timeline as per the validation contract, CER delivery commitment by PP/CME, etc.
If the site visit cannot be postponed but are not conducted due to force majeure conditions, CEC will discuss and reach an agreement with the PP/CME to implement remote validation supported by ICT application as an optional standard auditing techniques and temporary measure. The assigned validation team will perform the remote validation according to CEC operation instruction CEC-4022C-C/1.0
5.7 Information assessment
Based on the document review, background checks, on-site inspection and access through telephone or e-mail, the validation team should use standard auditing techniques to further assess the accuracy of information provided by the project participants, including the project activities similar to the proposed PA or PoA/CPA, or the use of technology similar to the PA or PoA/CPA, available references on these projects or technologies, as well as the applicability of the formula used in the methodology and the accuracy of calculation, and so on.
5.8 Draft a draft validation report and submit the CLs/CARs/FARs
Based on a full review of project, the validation team should draft the draft validation report using the valid version of the relevant validation report form. The draft validation report must discuss the validation team’s validation opinions one by one in accordance with the requirements of vvs.
In the process of validation of the PA or PoA/CPA, if the validation team find a question that should be further explained, researched or with additional questions, in order to confirm whether the project PA or PoA/CPA conforms to CDM requirements and can obtain reliable emission reductions or net anthropogenic GHG removals, the validation team must ensure correct identification of these issues. At the same time, the validation team should submit CLs/CARs/FARs to the project owner or the project commissioned party.
The validation team shall raise a corrective action request (CAR) if one of the following situations occurs:
(a)The PP/CME have made mistakes that will influence the ability of the proposed CDM PA or PoA/CPA to achieve real, measurable, verifiable and additional GHG emission reductions or net anthropogenic GHG removals;
(b)The applicable CDM rules and requirements have not been met;
(c)There is a risk that GHG emission reductions or net anthropogenic GHG removals cannot be monitored or calculated.
The validation team shall raise a clarification request (CL) if information is insufficient or not clear enough to determine whether the applicable CDM requirements have been met.
The validation team shall raise a forward action request (FAR) during validation to identify issues related to project implementation that require review during the first verification of the project activity. The validation team shall not raise a FAR that relates to the CDM requirements for registration.
5.9 Finalization of draft validation report
When the project participants modify the project design, rectify the PDD, PoA-DD or CPA-DD, or provide additional explanation or evidences that satisfied by the validation team’s concern, the validation team will resolve or close out the CARs and CLs, and the validation team leader can complete or entrust team members to complete the final validation report.
The draft final report should reflect the communication and results of project adjustment after the release of the draft validation report, and also reflect the resolution of CARs and CLs, as well as modified project documents.
The draft final validation report must contain the final views of validation team. The validation opinions should at least include:
(1)The applied standard, methodology, tools and guidelines, forms, GWPs，validation process, as well as a summary of validation criteria;
(2)The description of project component or issues not covered in the validation process;
(3)A summary of validation conclusions;
(4)The statement of validation to prospective emission reductions or net anthropogenic GHG removals;
(5)The conclusion on whether the proposed CDM PA/PoA/CPA is consistent with the existing standards. It includes the positive validation opinion or negative opinion.
(6)if applicable, statement on whether a document describing how the project participants intend to monitor sustainable development co-benefits of the proposed CDM project activity was developed by the project participants separately from the monitoring plan
5.10 Independent technical review
After the submission of the draft final validation report by the validation team, QA Division shall be responsible for organizing the technical review team to take the technical review to the validation report independently.
The decision of technical review (TR) on the project shall be made independently to validation team of the same project, namely the member of the project validation team can’t be as the independent technical review personnel of the same project.
Technical review team members make an assessment of the validation opinion and report independently to ensure the validation has been conducted in accordance with the related requests of CDM modalities and procedures, VVS, applied standard/methodology of project and the items of CDM other relevant criterions. After all of questions raised in technical review were closed out by validation team, QA Division shall be responsible for the completeness check of the final validation report, then the final validation report is just regarded accomplished.
5.11 Final decision and approval
(1)The final validation report and the validation process shall be checked by the CDM Director, and then reported to the CDM Quality Manager, who makes the final decision on the validation opinion and report.
(2)The final validation report shall be approved and issued by the General Manager.
5. 12 Request for registration
The QA Division will transfer the uploaded project documents to the CI Division. CI Division, in accordance with the requirements of EB, will upload project documents to CEC interface, including all of the documents required in the application form.
5.13 Record Requirements
CDM validation team should implement the validation activities as per related requirements and keep enough relevant records and evidences to fulfill the traceability requirement.
6. Response for request for review
During the stage of completeness check, information and reporting check, publishing the application of registration on website after submitting the request for registration, if EB request for review, then:
(1)CI Division is responsible for achieving and transferring the EB’s review opinions to PI Division;
(2)PI Division shall organize the validation team to take correction at once after achieving the review opinions;
(3)According to the questions of request for review by EB, the validation team shall analyze the reasons which cause the request for review, put forward the corrective measures. Clearly, completely and accurately clarify the questions requested by EB according to the related requirements of CDM and related items of VVS, if necessary, request the PP to further provide the evidences and supply documents;
(4)After all of the corrective measures are accomplished, the validation team submits the response and related documents to QA Division. According to step 5.10-5.12 above, QA Division organize technical review and audit of validation report. After approved by General Manager, re-submitting the reply to EB by CI Division. All of necessary documents shall be submitted together accordance with requests when re-submitting the reply to EB.
(5)PI Division is responsible for developing preventive measures and organizing to implement in order to prevent the same questions to happen again.
7. Specific validation requirement for PoA project
7.1 General
Validation principles, approaches, means and process management requirements above are applicable to the validation activities for PoA projects. Also the validation team shall conduct a thorough and independent assessment of a proposed CDM PoA against the applicable CDM rules and requirements, including those specified in the “CDM project standard for programmes of activities”.
For request for registration of PoA, the consistent validation criteria shall be applied during the whole validation process:
(i)To the requirements of the applicable approved methodologies and, where applicable, the applicable approved standardized baselines throughout the crediting period(s);
(ii)To CDM PoAs with similar characteristics such as a similar application of the applicable approved methodologies, approved standardized baselines, use of technology, time period or region;
(iii)To expert judgments, over time and among CDM PoAs/CPAs;
The whole validation process and opinions, including the process undertaken to validate the generic CPA and findings, shall be reported in the valid and appropriate validation report for PoA.
7.2 Specific validation requirement for inclusion of CPA
Validation principles, approaches, means and process management requirements above are applicable to the validation activities for PoA projects. Also the validation team shall conduct a thorough and independent assessment of inclusion of CPA, including assess whether the proposed CPA complies with the corresponding generic CPA-DD in the latest version of the registered PoA-DD, including the eligibility criteria for the inclusion of CPAs in the registered CDM PoA and relevant CDM rules and requirements.
It is mandatory to conduct an on-site inspection at validation for the proposed CPA if:
(a)Its estimated annual average of GHG emission reductions or net anthropogenic GHG removals is more than 100,000 t CO2 eq; or
(b)There is pre-project information that is relevant to the requirements for inclusion of the CPA and may not be traceable after the inclusion.
For cases that are not referred to in paragraph above, it is optional to conduct an on-site inspection at validation. If the validation team does not conduct an on-site inspection as a means of validation, it shall describe the alternative means used and justify that they are sufficient for the purpose of validation.
The whole validation process and opinions shall be reported in the valid and appropriate validation report for CPA.
8. Specific validation requirement on post-registration activities
8.1 General
According to the latest vvs, post-registration changes for CDM PA/PoA include:
1)temporary deviations from the registered monitoring plan, applied monitoring methodology, applied standardized baseline or other methodological regulatory document;
2)permanent changes (i. corrections; ii. Changes to the start date of the PA or CPAs crediting period; iii. Inclusion of monitoring plan; iv. Permanent changes to the registered monitoring plan, or permanent deviation of monitoring from the applied methodologies, standardized baselines, or other applied standards or tools; v. CDM-PA changes to the project design or CDM-PoA change to the programme or project design；vi. Addition of CPA inclusion template; vii. Change of CME).
Validation principles, approaches, means and process management requirements above are applicable to the validation activities for post-registration activities. On-site inspection requirements at validation for post-registration activities is the same with that in section 5.6 above.
If it is determined that the proposed or actual post-registration changes to the registered CDM PA or PoA/CPA comply with the relevant CDM rules and requirements, the validation team shall issue a positive validation opinion and submit a request for approval of changes either prior to or together with the submission of the request for issuance of CERs in accordance with relevant requirements in the “CDM project cycle procedure for project activities” “CDM project cycle procedure for programmes activities”. If it is determined that the proposed or actual post-registration changes to the registered CDM PA or PoA/CPA do not comply with the relevant CDM rules and requirements, the validation team shall issue a negative validation opinion.
The validation team shall determine whether the revised PA-PDD or PoA-DD/CPA-DD reflecting the post-registration changes were prepared in both track-change and clean versions, and were completed using the valid version of the applicable form.
If the project participants used a later valid version of the PA-PDD or PoA-DD/CPA-DD form than the version used for the registered version, the validation team shall determine whether the information transferred to the later valid version of the form is materially the same as that in the registered PA-PDD or PoA-DD/CPA-DD.
The whole validation process and opinions shall be reported in the in the valid and appropriate validation report for post-registration changes.
8.2 Change of CME of PoA
If subsequent to the registration of the CDM PoA, the CME has changed, CEC undertaking the next inclusion of a proposed CPA, will submits the next request for issuance of CERs for the PoA, or submits the next post-registration change request for the PoA, whichever is earlier, shall determine whether the new CME:
(a)Obtained a new letter of authorization from each host Party stating the change and confirming the authorization of its coordination of the PoA;
(b)Provided a confirmation that the PoA will be developed and implemented with the same framework as described in the registered PoA-DD;
(c)Demonstrated compliance with requirements related to the operational and management arrangement.
8.3 Specific requirements for afforestation and reforestation PA/CPA
(1)The validation team shall determine whether there are types of changes specific to include A/R CPAs, and, if there are, determine whether the changes comply with the relevant requirements in the CDM project standard.
(2)In the case of actual changes, the validation team shall, by means of an on-site inspection (where conducted in accordance with part 8 above), interviews with relevant personnel and/or a review of the revised PDD submitted by the PP/CME that describes the nature and extent of the actual changes, determine whether this description accurately reflects the implementation, operation or monitoring of the modified PDD.
(3)In case of actual changes, the validation team shall determine whether the changes in the revised PDD are a complete and accurate reflection of the actual A/R information.
9. Specific validation requirement for RCP of CDM PA/PoA/CPA
Validation principles, approaches, means and process management requirements in above section 5 are applicable to the validation activities for RCP of CDM PA/PoA/CPA. Also the validation team shall conduct a thorough and independent assessment of a proposed RCP of CDM PA/PoA/CPA against the applicable CDM rules and requirements.
On-site inspection requirements at validation for RCP of CDM PA/PoA/CPA is the same with that in section 5.6 above.
when start a RCP validation, the validation team shall confirm the actual implementation status of the registered CDM PA/PoA/CPA in the first crediting period. The validation process and opinion for this confirmation shall be reported in the validation report. If the registered CDM PA/PoA/CPA has not been implemented in the first crediting period, the validation team shall forward this information to the CI Division, then CI Division shall seek an approval from EB to proceed with a request for renewal of crediting period before submission of the request.
The whole validation process and opinions, including the conclusions on actual implementation status, baseline, the estimated GHG emission reductions or net anthropogenic GHG removals, the monitoring plan and the crediting period in the updated PDD or PoA-DD/CPA-DD, shall be reported in the valid and appropriate validation report for RCP.
10. Specific validation requirement for re-inclusion of CPA
The validation team shall determine whether the excluded CPA for which re-inclusion in the same or different registered CDM PoA is being sought meets the conditions for re-inclusion specified in the CDM project standard for PoA. The validation team shall assess whether the excluded CPA meets the specific conditions for re-inclusion specified in the CDM project standard for PoA with regard to:
(a) A declaration on the exclusion history;
(b)The crediting period type, duration and end data;
(c)The compliance with the latest version of the PoA-DD including eligibility criteria for inclusion of CPAs in the PoA as specified in the corresponding generic CPA-DD in the PoA-DD;
(d)The continuity of monitoring;
(e)The rectification of non-compliance if the CPA was excluded as a result of erroneous inclusion and is to be re-included in the same registered CDM PoA, and the compensation of erroneously issued CERs if applicable.
CEC shall prepare a validation report for re-inclusion of an excluded CPA in the same or different registered CDM PoA using the valid version of the validation report form for inclusion of CPAs.
Verification / Certification
1. Purpose and Scope
The procedure aims to ensure the verification and certification activities of CEC to be a thorough, independent assessment on GHG emission reductions or net anthropogenic GHG removals achieved by a registered CDM PA or PoA/CPA as per the relevant provisions of UNFCCC and EB.
The procedure stipulates the responsibility, process flow and requirements for verification and certification functions;
2. Reference
CDM Accreditation Standard v7.0
CDM validation and verification standard for project activities v3.0
CDM validation and verification standard for programmes of activities v3.0
CDM project standard for project activities v3.0
CDM project standard for programmes of activities v3.0
CDM project cycle procedure for project activities v3.0
CDM project cycle procedure for programmes of activities v3.0
3. Responsibilities
3.1PI Division is responsible for implementation and coordination of verification/certification functions.
3.2The appointed verification team shall implement and complete the verification task, and compile the final verification and certification report.
3.3QA Division is responsible for organizing the technical reviews of the draft verification and certification report, after technical reviewing, QA Division is responsible for the completeness check of the final verification and certification report.
3.4CI Division is responsible for the necessary communication with the PPs or CMEs.
3.5CDM Director is responsible for verifying the final verification/certification report.
3.6CDM Quality Manager is responsible to make the final decision of verification/certification opinion.
3.7General Manager is responsible to approve and issue the final decision on verification/certification opinion and the final verification/certification report.
4. Verification Requirements
4.1Principles for verification
The following principles guide the preparation, execution, and reporting of verification activities.
(1) Independence Remain independent of the activity being verified, and free from bias and conflict of interest. Maintain objectivity throughout the verification to ensure that the findings and conclusions will be based on objective evidence generated during the verification.
(2) Ethical conduct Demonstrate ethical conduct through trust, integrity, confidentiality and discretion throughout the verification process.
(3) Fair presentation Reflect truthfully and accurately verification activities, findings, conclusions and reports. Report significant obstacles encountered during the verification process, as well as unresolved, diverging opinions among verifiers, the responsible party (e.g. the secretariat/EB) and the client (e.g. project participants).
(4) Due professional care Exercise due professional care and judgment in accordance with the importance of the task performed and the confidence placed by clients and intended users. Have the necessary skills and competences to undertake the verification.
Prior authorization notes before verification:
For verification of a registered CDM PA, if CEC has performed validation (including for registration or renewal of crediting period) for the registered CDM PA, and wishes to perform this verification for the same project, CEC shall obtain authorization to do so from the Board in accordance with the “CDM project cycle procedure for project activities”, adequate justification shall be demonstrated for the authorization. CEC may perform verification without obtaining authorization from the Board to do so for:
(a) A registered small-scale CDM project activity or a registered small-scale A/R CDM project activity for which CEC has performed the such validation activity;
(b) Any registered CDM PA for which CEC has performed the validation of post-registration changes.
For verification of a registered CDM PoA, if CEC has performed validation for registration or renewal of PoA period, or inclusion or renewal of crediting period of any of the CPAs covered by the verification, and wishes to perform verification for the same PoA, CEC shall obtain authorization to do so from the Board in accordance with the “CDM project cycle procedure for programmes of activities”. CEC may perform verification without obtaining authorization from the Board to do so for a registered PoA for which CEC has performed validation of post-registration changes of the PoA or any of the CPAs covered by the verification.
4.2 Verification approach
The general verification approaches are mainly as below:
(a)Apply the most recent applicable decisions and guidance provided by the Board.
(b)1Determine whether each CDM PA meets all applicable CDM rules and requirements, including those specified in the “CDM project standard for project activities”, relevant methodologies, tools and standardized baselines.
(b)2Determine whether each CDM PoA or CPA meets all applicable CDM rules and requirements, including those specified in the “CDM project standard for programmes of activities”, relevant methodologies, tools and standardized baselines.
(c)Assess the accuracy, conservativeness, relevance, completeness, consistency and transparency of the information provided by the project participants.
(d)Determine whether information provided by the project participants or CME is reliable and credible.
(e)Apply consistent verification criteria:
(i)To the requirements of the applicable approved methodologies and, where applicable, the applicable approved standardized baselines throughout the crediting period(s);
(ii)To CDM PAs or PoAs with similar characteristics such as a similar application of the applicable approved methodologies, approved standardized baselines, use of technology, time period or region;
(iii)To expert judgments, over time and among CDM PAs or CDM PoAs/CPAs;
(f)Base its findings and conclusions on objective evidence and conduct all validation activities in accordance with CDM rules and procedures.
(g)Not omit evidence that is likely to alter the validation opinion.
(h)Present information in the validation report in a factual, neutral and coherent manner and document all assumptions, provide references to background material, and identify changes made to the documentation.
(i)Safeguard the confidentiality of all information obtained or created during the validation.
(j)Use of and compliance with applicable standards.
(k)Use of applicable forms.
(l)Use of applicable global warming potentials.
4.2.2 Quality of evidence
When verifying the reported emission reductions, the verification team shall confirm that there is an audit trail that contains the evidence and records that validate or invalidate the stated figures. It shall include the source documents that form the basis for assumptions and other information underlying the GHG data.
When assessing the audit trail, the verification team shall:
(a)Address whether there is sufficient evidence available, both in terms of frequency (time period between evidence) and coverage (in covering the full monitoring period);
(b)Address the source and nature of the evidence (external or internal, oral or documented);
(c)Cross-check the monitoring report against other sources such as comparable information, where available, from sources other than those used in the monitoring report to determine whether the stated figures are correct.
The verification team shall only certify emission reductions that are based on verifiable evidence
5. Verification Process Management Requirements
5.1. Process flow chart
The detailed work flow chart is indicated in the following figure 1.
The procedure for verification/certification implementation is initiated since the contracted signed. The verification team should, as per related requirements, complete all aspects of verification task undertaken by CEC within the regulated period.
During the entire verification process, CEC shall apply the standard auditing techniques, including the desk review and on-site inspection, where applicable, using sampling approach.
Figure 1: CDM PA/PoA verification Process
5.2Selection of verification team
PI Division is responsible for planning the implementation arrangement of the CDM project or PoA verification and appointing the presupposed verification team and final verification team following the specific requirements part 5.10 of Procedure for selection and allocation of team for VV functions(CEC-3012C）.
5.3Verification task arrangement
The verification team leader has overall responsibility for the implementation of the verification of the proposed project activity and quality control. According to the requirements of Validation and Verification Standard (VVS) and the commitment on relevant service in CDM service Contact, the verification team leader should manage all aspects of verification task undertaken within the regulated period, including:
(1)Making the verification Plan (time, location, assessment principle, task allocation among verification team members and verification content etc.).
(2)Planning and making effective use of human resources and managing verification teams.
(3)Planning and organizing work effectively and performing it within the agree time schedule, to prioritize and focus on matters of significance.
(4)Representing the verification team in communications with the CEC’s clients.
(5)Preventing and resolving conflicts.
(6)Managing the verification process and concluding the decisions affecting the verification process.
(7)Taking charge of drafting the verification report and the subsequent requests of possible corrective/clarification action.
(8)Leading the team to reach conclusions on all aspects of verification and complete the verification report.
Team members shall complete the assigned verification task individually or together with the team leader. It is the duty of team members to be familiar with the PA-PDD/PoA-DD/CPA-DD and other project documents related to their selves verification task.
5.4Monitoring report publication
After received the monitoring report provided by PP/CME, the verification team shall start the procedure for public consultant process. CI Division shall upload the monitoring report (MR) onto UNFCCC website for 21-days publicity.
During the verification process, the verification team needs to consider the comments received from publicity, and the verification report is required to contain concrete measures taken in response to the received comments during the verification. If the views or opinions have not been adequately demonstrated or the project activity is not in conformance to CDM requirements, the verification team shall require PP/CME to further clarify these opinions.
5.5Document review
At the same time of global public consultant process, the verification team shall conduct the document review process, involving:
(i)A review of the data and information presented to verify their completeness.
(ii)A review of the monitoring plan and monitoring methodology, including applicable tools, paying particular attention to the frequency of measurements, the quality of metering equipment including calibration requirements, and the quality assurance and quality control procedures.
(iii)An evaluation of data management and the quality assurance and quality control system in the context of their influence on the generation and reporting of emission reductions.
The following documents should be reviewed (including but not limited):
a)Monitoring report to verify that it is as per the standardized forma.
b)Emission reduction spreadsheet and Emission reduction quantification evidence.
c)The registered PA-PDD or PoA-DD/CPA-DD and the monitoring plan, including any approved revised monitoring plan and/or changes, and the corresponding validation report.
d)Previous verification reports, if any.
e)The applied monitoring methodology, where applicable, the applied standardized baseline.
f)If applicable, the monitoring results of sustainable development co-benefits of the registered CDM PA or PoA, if requested to verify this by the PP/CME.
g)Any other information and references relevant to the GHG emission reductions (e.g. IPCC reports, data on electricity generation in the national grid or laboratory analysis and national regulations).
h)Other documents, such as CDM manual, process diagrams, technical drawings and the manuals of the equipment can be assessed together.
5.6On-site inspection
5.6.1On-site visit
Generally, on-site inspection is mandated for each verification activity whatever volume of the GHG ERs or net anthropogenic GHG removals, it will be performed after the 21-days monitoring report publicity, including the verification for the included CPA if:
(a)It is the first verification for CEC with regard to this CPA;
(b)More than three years have elapsed since the last on-site inspection conducted for verification for the CPA; or
(c)The CPA has achieved more than 300,000tCO2eq of GHG emission reductions or net anthropogenic GHG removals since the last verification when an on-site inspection was conducted.
The on-site inspection process based on the On-site Visit Plan and focus on the followings:
(i)An assessment of the implementation and operation of the registered project activity as per the registered PDD/PoA-DD/CPA-DD or any approved revised PDD/PoA-DD/CPA-DD;
(ii)A review of information flows for generating, aggregating and reporting the monitoring parameters;
(iii)Interviews with relevant personnel to determine whether the operational and data collection procedures are implemented in accordance with the monitoring plan in the PDD/PoA-DD/CPA-DD;
(iv)Cross checks between information provided in the monitoring report and data from other sources such as plant logbooks, inventories, purchase records or similar data sources;
(v)A check of the monitoring equipment including calibration performance and observations of monitoring practices against the requirements of the PDD/PoA-DD/CPA-DD, and the applied methodologies including applicable tool(s), and where applicable, the applied standardized baselines;
(vi)A review of calculations and assumptions made in determining the GHG data and emission reductions or net anthropogenic GHG removals;
(vii)An identification of quality control and quality assurance procedures in place to prevent or identify and correct any errors or omissions in the reported monitoring parameters.
(viii)Remain issue: a) whether the project participants have addressed the FARs identified during validation or previous verification(s); b) if applicable, the monitoring results of sustainable development co-benefits of the registered CDM PA or PoA/CPA, if requested to verify this by the project participants.
For the verification visit to site, the following personnel, at minimum, shall participate in the visit:
(a)The team leader;(in case of site visit to multiple sites, the team leader is required to visit one or more sites, as appropriate);
(b)The team member(s) qualified in the technical area(s) of the CDM PA or PoA being validated.
5.6.2Remote verification when no mandatory site visit under force majeure conditions
According to CDM-EB113-A07
If the site visits cannot be postponed, CEC shall justify in the verification report that why the site visits cannot be postponed, including the demonstration of a significant impact of delaying the site visits on CEC/PP/CME. The justification could include commitment/timeline as per the verification contract, CER delivery commitment by PP/CME, etc.
If the site visit cannot be postponed but is not conducted due to force majeure conditions, CEC will discuss and reach an agreement with the PP/CME to implement remote verification supported by ICT application as an optional standard auditing techniques and temporary measure. The assigned verification team will perform the remote verification according to CEC operation instruction CEC-4022C-C/1.0
5.7Draft a draft verification/certification report and submit the CLs/CARs/FARs
After the on-site inspection, the verification team shall identify, discuss and conclude in the verification report issues related to the monitoring, implementation and operations of the registered CDM PA or PoA that would be a threat to achieve emission reductions or influence the monitoring and reporting of emission reductions.
(1)The verification team shall raise a CAR if one of the following situations occurs:
(a)Non-compliance with the monitoring plan or methodology are found in monitoring and reporting and has not been sufficiently documented by the project participants, or if the evidence provided to prove conformity is insufficient;
(b)Modifications to the implementation, operation and monitoring of the registered project activity has not been sufficiently documented by the project participants;
(c)Mistakes have been made in applying assumptions, data or calculations of emission reductions that will impact the quantity of GHG emission reductions or net anthropogenic GHG removals;
(d)Issues identified in a FAR during validation to be verified during verification or previous verification(s) have not been resolved by the project participants.
(2)The verification team shall raise a CL if information is insufficient or not clear enough to determine whether the applicable CDM requirements have been met.
(3)The verification team shall raise a FAR during verification for actions if the monitoring and reporting require attention and/or adjustment for the next verification period.
In the meantime, the verification team shall start to compile the draft verification and certification report using the valid and appropriate version of the relevant verification and certification report form. The verification team shall resolve or “ close out” CARs and CLs only if the project participants rectify the monitoring report, or provides additional explanations or evidence that satisfy the verification team’s concern.
The draft verification and certification report shall provide the following:
(a)A summary of the verification process and the scope of verification.
(b)Details of the verification team, technical experts, and internal reviewers involved, together with their roles in the verification activity and details of who conducted the on-site visit.
(c)Findings of the desk review, on-site inspection and sampling approach used by verification team. Where the verification team applied a sampling approach to the on-site inspection, the verification team shall include a description of how the sample size was determined and field check was carried out.
(d)All of the verification team’s findings and conclusions as to whether:
(i)The project activity has been implemented and operated in accordance with the registered PDD or any approved revised PDD;
(ii)The monitoring plan complies with the monitoring methodology and the actual monitoring complies with the monitoring plan, including compliance with any guidance provided by EB regarding deviations from the provisions of a registered plan and/or methodology;
(iii)The data and calculation of GHG emission reductions or net anthropogenic GHG removals have been assessed to correctly support the emission reductions being claimed.
(e)A list of each parameter specified by the monitoring plan and a statement on how the values in the monitoring report have been verified.
(f)A statement that identifies any changes to the registered PDD/PoA-DD/CPA-DD, and their date of approval by EB.
(g)An assessment and close-out of any CARs, CLs or FARs issued to the project participants.
(h)An assessment of remaining issues from the previous verification period, if appropriate.
(i)A conclusion on the verified amount of GHG emission reductions or net anthropogenic GHG removals achieved and.
(k)Information on quality control within the team and in the verification process.
(l)Reference.
For CDM PA or PoA, CEC shall, based on its verification, certify in writing that, during the specified time period, the registered CDM PA or some or all of the included CDM CPAs in the registered CDM PoA achieved the verified amount of GHG emission reductions or net anthropogenic GHG removals that would not have occurred in the absence of the project activity or the CPAs.
If applicable, the verification report shall provide the assessment process, conclusion on the sustainable development co-benefits monitoring results of the registered CDM PA/PoA/CPA. However, the findings from this assessment shall have no bearing on the final verification opinion of CEC.
CEC will inform the project participants, stakeholders and EB of its certification decision in writing. This part of the work will be completed immediately after the certification process. The certification report will be made public. Certification report submitted to EB is an equivalent demand for request for issuance of the certificated emission reductions.
5.8 Technical review (TR)
After submit the verification/certification reports by the verification team, QA Division is responsible for organizing the technical review team to assess the reports independently.
It must be done independently that the assessment decision of CDM PA or PoA-DD and CPA-DD, namely the verification team member can’t act as the independent technical review personnel of the same project.
Technical review team members make an assessment of the verification and certification opinion and report independently to ensure the verification and certification has been conducted in accordance with the related requests of CDM modalities and procedures, vvs-PA/vvs-PoA, applied methodology of project and the items of CDM other relevant criterions. After all of questions raised in technical review were closed out by verification and certification team, QA Division shall be responsible for the completeness check of the final verification and certification report, then the final verification and certification report is just regarded accomplished.
5.9Final decision and approval
The final verification/certification report and the verification process shall be checked by the CDM Director, and then reported to the CDM Quality Manager, who makes the final decision on the verification/certification opinion and report. The final verification/certification report shall be approved and issued by the General Manager.
5.10Request for issuance
QA Division conveys request for issuance and relevant documents to CI Division.
CI Division uploads request for issuance and relevant documents according to the EB requirements.
5.11Record requirements
CDM verification team should implement the verification activities as per related requirements and keep enough relevant records and evidences to fulfill the traceability requirement.
5.12Response for request for review
During the stage of completeness check, information and reporting check, publishing the application of issue on website after submitting the request for registration, EB may request for review, then:
1)CI Division is responsible for achieving and transferring the EB’s review opinions to PI Division;
2)PI Division shall organize correction at once after achieving the review opinions;
3)According to the questions of request for review by EB, the verification team shall analyze the reasons which cause the request for review, put forward the corrective measures aim at the reasons. Clearly, completely and accurately clarify the questions requested by EB according to the CDM related requirements including VVS, if necessary, request the PP/CME to further provide the evidences and supply documents;
4)After all of the corrective corrections are accomplished, submit the response and related documents to the QA Division. According to step above, QA Division organize the technical review and audit of verification /certification report. After approved by General Manager, submitting the reply to EB by the CI Division. All of necessary documents shall be submitted together accordance with requests when submitting the reply to EB.
5)PI Division is responsible for developing preventive measures and organizing their implementation in order to prevent the same questions to happen again.
6. Specific verification requirements for SSC PA/CPA
The verification team shall determine whether the registered SSC PA/CPA remains within the limit of the type of small-scale project activities defined in the CDM project standard for PAs/PoAs. If the project activity exceeds the limit of its type in any year of the crediting period, the verification team shall assess whether this was caused by the post-registration changes validated in accordance with relevant requirements. If the verification team determines that there are no such post-registration changes to the project activity, and therefore the scale of the project activity does not change, for a Type II or Type III small-scale CDM PA/CPA, it shall assess whether the calculated GHG emission reductions during this particular year were capped at the amount calculated with the limit of its type.
The verification process, approaches and means, management requirements above are applicable for verification of SSC Pas/CPAs. The whole verification process and opinions shall be reported in the valid and appropriate verification report for SSC PA/CPA.
7. Specific verification requirements for afforestation and reforestation PAs/CPAs
At the first verification for an A/R CDM PA/CPA, CEC shall, in accordance with paragraph 34 (d) of the CDM A/R M&Ps, confirm those areas of land for which the control over the project activity has been established by the project participants since validation.
As a part of the first verification and certification report for an A/R CDM PA/CPA, CEC shall confirm that the boundary of the project activity geographically delineates exclusively the A/R project activity under the control of the project participants.
If temporary CERs (tCERs) were issued based on the previous verification and certification, CEC shall confirm that the current verification and certification is for the first time in the current commitment period. If long-term CERs (lCERs) were issued based on the previous verification and certification, CEC shall confirm that the current verification and certification is within eight years of the date when the previous certification report was submitted until the end of the current crediting period.
For lCERs, if the monitoring period falls partly in the first commitment period and partly in the second commitment period of the Kyoto Protocol, CEC shall confirm that all net anthropogenic GHG removals achieved since the last verification are allocated to the second commitment period. For tCERs, for any issuance, CEC shall confirm that all net anthropogenic GHG removals achieved since the start of the project activity are allocated to the commitment period in which the monitoring period ends.
8. Application of materiality
CEC plans and conducts a verification to a registered CDM PA or PoA using the concept of materiality and shall achieve a reasonable level of assurance that the reported GHG emission reductions or net anthropogenic GHG removals are free from material errors, omissions or misstatements.
An omission, misstatement, or erroneous reporting of information is material if it might lead, at an aggregated level, to an overestimation of the total emission reductions or removals achieved by a registered CDM PA equal to or higher than the following thresholds: (a) 0.5 per cent of the emission reductions or removals for registered CDM project activities achieving a total emission reduction or removal equal to or more than 500,000 tonnes of carbon dioxide equivalent per year; (b) 1 per cent of the emission reductions or removals for registered CDM project activities achieving a total emission reduction or removal of between 300,000 and 500,000 tonnes of carbon dioxide equivalent per year; (c) 2 per cent of the emission reductions or removals for registered large-scale CDM project activities achieving a total emission reduction or removal of 300,000 tonnes of carbon dioxide equivalent per year or less; (d) 5 per cent of the emission reductions or removals for registered small-scale CDM project activities other than registered CDM project activities covered under subparagraph (e) below; (e) 10 per cent of the emission reductions or removals for the type of registered CDM project activities referred to in decision 3/CMP.6, paragraph 38 (referred to as microscale project activities).
An omission, misstatement or erroneous reporting of information is material if it might lead, at an aggregated level, to an overestimation of the total GHG emission reductions or net anthropogenic GHG removals achieved by a registered CDM PoA equal to or higher than the following thresholds: (a) 0.5 per cent of the emission reductions or removals for registered CDM PoAs achieving a total emission reduction or removal equal to or more than 500,000 tonnes of carbon dioxide equivalent per year; (b) 1 per cent of the emission reductions or removals for registered CDM PoAs achieving a total emission reduction or removal of between 300,000 and 500,000 tonnes of carbon dioxide equivalent per year; (c) 2 per cent of the emission reductions or removals for registered CDM PoAs achieving a total emission reduction or removal of 300,000 tonnes of carbon dioxide equivalent per year or less; (d) 5 per cent of the emission reductions or removals for registered CDM PoAs comprised only of small-scale CPAs other than registered CDM PoAs covered under subparagraph (e) below; (e) 10 per cent of the emission reductions or removals for registered CDM PoAs comprised only of microscale CPAs.
When planning the verification, CEC shall identify the materiality threshold in paragraph above that corresponds to the amount of emission reductions or removals the specific type of registered CDM PA or PoA will achieve; Understand the environment in which the registered CDM project activity operates, the sources of project emissions within the project boundary and the leakage, the monitoring activities, the equipment used to monitor or measure activity data, the origin and application of data used to calculate or measure the emissions, data flow, the internal quality control system, and the overall organization with respect to monitoring and reporting; Conduct a risk assessment to identify and assess the risks of individual or aggregated material errors, omissions or misstatements that may occur within the threshold based on elements in above; Design verification plans, audit procedures and sampling plans whose type, timing and extent are based on and are responsive to the assessed risks of material errors, omissions or misstatements.
When conducting the verification, CEC applies verification plans, audit procedures and sampling plans; Assesses potential errors, omissions and misstatements against the materiality threshold to determine whether they are material individually or in aggregate and whether further audit procedures are needed.
In the verification report, CEC shall report: The risks, the risk assessment undertaken and how the verification plans and sampling plans were designed to respond to these risks and ensure that all material errors, omissions or misstatements were detected; Whether and how the verification plans and sampling plans were revised to take into account the need for further audit procedures due to the nature/type of errors, omissions or misstatements detected; How materiality was applied in determining whether a detected error, omission or misstatement was material or immaterial either individually or in aggregate
Note：This information is publicized in both English and Chinese. In the event of any conflict or ambiguity or discrepancy between the two versions, the Chinese version shall prevail.