110630 DNA Forum PoA2NAMA Final

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    PoA to NAMA: Possibilities for Evolution

    Session 4: Programme of ActivitiesRegional African CDM DNA Forum

    Palais des Congrs - Marrakech, 9 July 2011

    Manuel Cocco

    Business Development

    Manager

    South Pole Carbon Asset

    Management Ltd.

    [email protected]

    Prepared by South Pole on the

    basis of analysis conducted for:

    PoA Support Center

    Ingo Puhl

    Managing Partner

    South Pole Carbon Asset

    Management Ltd.

    [email protected]

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    Presentation of Findings of a Recent Study for KfW/BMU On the Road from PoA to NAMA: How to develop a NAMA by scaling-up ongoing

    programmatic CDM activities (to be published in July 2011)

    Systematic analysis of four PoA case-studies

    Step-wise instructions to NAMA design based on PoA

    South Pole Case Study

    Integrating Thailands Feed-in-Tariff Policy into a PoA (FiT PoA) to Strengthen

    Renewable Energy Development

    Integrating a FiT PoA into a Future Renewable Energy Target under a NAMA approach

    Outlook

    A Program of Work to Simplify the Implementation of PoA under sector-targets using

    standardized baselines and/or NAMA frameworks

    Overview

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    Key Objectives Scaling-up mitigation action through carbon mechanisms to share the cost of mitigation

    actions with the international community

    Building on established mechanisms and existing capacities in developing countries, esp.

    capacity of DNA (critical)

    Approach/How?

    Integrate PoA design with domestic policy frameworks by aligning key PoA design criteria

    with relevant policies (i.e. eligibility criteria, baseline setting, MRV systems, management

    and operation entities)

    Develop standardized & aggregate approaches (for baselines and MRV) whenever

    possible

    Integrate PoA design with voluntary, appropriate targets (NAMA)

    Benefits of this Approach

    Build on operational mechanism (no need to wait for agreement on new mechanism)

    De-centralize the operation of the CDM EB and reduce bottlenecks

    Shift responsibility and authority to DNA (which will need to develop capacity)

    Move from project/program to sector-level management, driven by domestic policy and

    management of environmental integrity on sector-level

    Increase net benefits to producers of the environmental benefits (as result of reducedtransaction costs and broad participation)

    What Drives the Need to Scale-Up Mitigation Action

    on the Basis of PoA Approach?

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    Study

    On the Road from PoA to NAMA

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    How to Scale-up PoA(lessons learnt from the KfW/BMU analysis)

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    Policy priorities should drive PoA design in relation to:

    Eligibility criteria

    Baseline setting

    MRV

    Implementation arrangements and management & operation procedures

    DNA develop/submit standardized baselines for such policy-driven PoA

    Upgrade from PoA to NAMA by building on key PoA design elements and

    standardized baselines:

    NAMA eligibility criteria based on PoA criteria plus additional relevant

    activities that dont meet PoA requirements (i.e. in relation to additionality) NAMA baseline setting based on standardized baselines

    NAMA target setting derived from NAMA baseline

    NAMA MRV requirements based on aggregate MRV procedure and PoA

    MRV requirements (top-down/bottom-up integration)

    NAMA implementation arrangements in cooperation with PoA CME

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    Which Existing CDM Procedures are Suitable to Design

    Scaled-Up Mitigation Actions on Basis of PoA

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    PoA DesignElement

    Applicable for Scaling Up (standard baselines & NAMA)

    Po

    AElements

    Eligibility Criteria Technical criteria that provide an objective basis to assess eligibility of afacility or activity (type of facility, unit sizes, type of intervention ..)

    Baseline Setting Standardized elements that have been developed for CDM methodologies:

    y large-scale benchmarks (carbon intensity of power grid, national orregional NRB usage rates)/ standardized (aggregate) baselines

    y deemed savings (average per household biomass use)

    y status-quo baselines

    y modelled baselines

    (can be used to determine NAMA baselines and NAMA targets)

    MRV A number of CDM MRV procedures are directly applicable:

    y deemed savings approach

    y methods that focus on large emission sources with simple MRV

    requirements that facilitate cost-effective MRV at facility level

    Implementationand Operation

    Some CME already operate at aggregate/sector scale and are also anintegral part of existing support mechanisms, could also manage NAMA.

    6

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    The Expanded Role of DNAs under Scaled-Up

    Approaches

    7

    Host country DNA are responsible for

    Shaping design criteria for policy-driven PoA

    Defining and submitting standardized baselines (COP decision 3/CMP 6)

    Provide input to NAMA design (scope/coverage/activities/baselines/targets),

    PoA integration and NAMA implementation arrangements

    Requesting NAMA readiness support

    Host country DNA play a key role in registering & operating scaled-upapproaches/NAMA

    MRV of activities/sources within the system targeted by scaled-up mitigation

    action (i.e. NAMA system)

    Providing incentive schemes to targeted activities

    Emissions true-up (environmental integrity)/enforcement

    Capacity Building Needs

    Regulatory Authority: to control eligibility criteria, strategic fit with domestic

    policy objective & ensure environmental integrity of the system

    More Autonomy: stronger role vs. CDM EB compared to current CDM to

    facilitate host-country-lead approach

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    Case Study

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    Case Study: Thailand Feed-in-Tariff PoA

    Feed-in-Tariff (FiT) Policy and RE Development

    Introduction of FiTmade RE development

    in Thailand successful

    The cost of this REpolicy has been borne

    by power consumers &tax payers

    There is strong politicalpressure to reduce

    these costs.

    CDM didn't contributea significant benefit to

    developers.

    0.0%

    2.0%

    4.0%

    6.0%

    8.0%

    10.0%

    12.0%

    14.0%

    16.0%

    0

    5000

    10000

    15000

    20000

    25000

    30000

    35000

    40000

    1995

    1996

    1997

    1998

    1999

    2000

    2001

    2002

    2003

    2004

    2005

    2006

    2007

    2008

    2009

    2010

    2011

    2012

    2013

    2014

    2015

    2016

    2017

    2018

    2019

    2020

    2021

    2022

    RE kWh % of RE

    Introduction of FiT

    based incentives

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    Carbon

    revenue

    Case Study: Thailand Feed-in-Tariff PoA

    Current FiT + Carbon vs. Integrated Payments

    VSPP

    adder

    Carbon

    revenue

    Current CDM Structure

    - High implementation cost

    - Delayedincome

    - High payment risk/uncertainty

    - CER marketprice uncertainty

    - Not bankable

    - So far: 0.008 THB/kWh

    - 0.3- 6.5 THB/kWh

    - At fullexpense of

    power users

    - Criticism on rate

    unfairness

    Future structure for

    participants in PoA

    - Much reducedinclusion cost

    increasenetpayments

    - No approval risks/cost

    - Access for all,incl. smallprojects- Could be 0.28 THB/kWh

    - Lower rates meanless burden

    onpower users: FIT POA can

    reducenetadder to

    consumers byapprox. 30%

    - Easier to justifypoliticallythe

    benefit oftheadder program

    Net VSPP

    adder

    Consumerrelief

    The red box could be up to 40 times larger then the green box !

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    Case Study: Thailand Feed-in-Tariff PoA

    PoA Design: integrate FiT and Carbon payments

    CCME

    CDMEB

    Intl. CER

    purchaserDNA

    PoA registrationandCER

    issuance

    Revenue from

    Sale ofCredits

    (PROFIT CENTER)

    - Prepare PoA PIN

    - Prepare PoADD

    - PrepareCPADD

    - Submit PoA PDDandCPA PDDs

    - Submitto DOE to validate

    - Submitto EBto register

    Approvedand

    authorized byDNA

    Communication with EB

    CPAs

    (Program Participants)

    - Signagreement with CME

    - Prepareinclusiondocs

    - Monitor theemission reduction

    - Receive share oftheCER revenues

    DOE

    Pass Eligibility

    Assessment

    Against PoA

    Transfer

    Power Users

    PEA

    ServiceAgreement

    A. Share of

    CER Revenue

    Tariff

    + FT Charges

    + Adder

    + CarbonAdder

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    Case Study: Thailand Feed-in-Tariff PoA

    Contribution of FiT PoA to RE Development

    Benefits of this Approach

    To reduce the cost toThai power consumers

    from 0.08 THB/kWh to

    0.05 THB/kWh in 2016

    To make sure that ALLemission reductions from

    RE count (not only from

    big projects that can

    afford high quality CDM

    service).

    To reduce transactioncosts by reducing CER

    origination costs.

    -1%

    1%

    3%

    5%

    7%

    9%

    11%

    13%

    15%

    0.0

    2.0

    4.0

    6.0

    8.0

    10.0

    12.0

    2010 2011 2016 2022

    Satang/kWh

    Cost of FiT policy [Satang/kWh]

    Net cost to consumer after taking into account ER value [Satang/kWh]

    % RE in generation

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    Case Study: Thailand Feed-in-Tariff PoA

    Integration of PoA with Future RE Targets

    PoA would still work under a future RE target:

    All emission reductions from new RE capacities are accounted for in the PoA.

    A share of the emission reductions that are needed to meet the domestic

    target are transferred to a national compliance account under sharing

    agreement.

    FiT is designed in anticipation of the sharing agreement (to ensure sufficientincentive is provided to developers).

    PoA supports MRV of national RE target

    PoA provides a fluent transition from current carbon market mechanism

    into future (sector-based) mechanism.

    A new mechanism (i.e. supported NAMA) could be added:

    Additional support payments (output-based) to increase the share of costs

    born by international community (and cap domestic contributions) and thus

    allow increasing the share of RE in Thailand.

    Key Issue: Criteria for the Setting of a National Target or Cost Cap

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    Outlook

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    The management of environmental integrity on sector-level

    creates Annex I conditions that should be reflected in rules.

    PoA that are located under a NAMA 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 J

    ISC 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.

    Simplified MRV requirements

    Appropriate monitoring plan, allowing combinations of CDM methodologies.

    Defined materiality thresholds.

    1

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    I.e. JI-style Pre-Conditions for PoA Simplification under NAMA

    SectorTargets (also applicable to standardized baselines)

    Parameter JI Scaled-Up Mechanism/NAMACountry Eligibility Party to KP Party to KP and submitted NAMA with UNFCCC

    NAMA Registry

    Target Has calculated and recorded

    its assigned amount units.

    Has determined NAMA baseline and target and

    has registered the NAMA under the UNFCCC.

    MRV system Has in place a national

    system for estimating of GHG

    emissions in compliance with

    international rules.

    Has established a 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

    1Source: JI Rulebook, Article 6http://www.jirulebook.org/3245

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    Recommendations to DNA

    Encourage host-country DNA to develop standardized baselines,

    conduct case-studies and pilot projects to study the linkage between

    NAMA design and scaled-up, policy-driven PoA procedures to facilitate

    bridging from PoA to NAMA,

    evolve & develop additional capacity for this new role, and

    Seek integration of discussions on NAMA and scaled-up PoA under

    sector targets.

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    Thank You for Your Attention

    Manuel Cocco, Business Development Manager

    [email protected]