CDM Methodologies: Clarifying Waste Energy Sources In PoAs Using ACM0012.pdf

Context:
A designated operational entity (DOE) seeks clarification on applying methodology ACM0012 to a programme of activities (PoA) in South Korea, involving waste heat network for an environmentally friendly industrial complex. The DOE questions if the PoA should limit waste energy sources to waste heat or include various sources like waste gas and pressure.

Analysis:

1. Homogeneity of CPAs: While not explicitly stated, Annex 38 (PoA registration procedures) implies all component project activities (CPAs) within a PoA should be homogeneous. Methodology ACM0012 is applicable to diverse waste energy recovery activities, so defining clear eligibility criteria for each type is crucial.

2. Multiple CPA Types: The DOE intends to include several CPA types under one PoA. This requires defining homogeneous CPA categories and providing detailed information in the PoA-DD (Programme of Activities Design Document). Current procedures allow this approach.

3. Adding CPAs Later: If multiple CPA types are initially submitted, the question arises if more can be added later. The Panel suggests clarifying conditions for adding new CPAs to ensure additionality and consistency.

4. Interactive Effects: When multiple waste energy recovery activities occur in one plant, interactive or cross-effects on emission reductions should be considered. ACM0012 accounts for such interactions; defining a group of interacting CPAs is technically feasible.

5. Guideline Recommendations:
- Clarify if a PoA can associate with multiple CPA types from different homogeneous project activity types.
- Specify if at least one CPA of each type must be validated before PoA registration.
- Define sampling criteria and clarify it should occur within each homogeneous CPA type.
- Identify methodologies where interactions between measures impact additionality or baseline scenarios, providing specific guidelines for PoA use.
- Require the PoA-DD to list all technologies/combinations covered, with eligibility criteria for CPA inclusion.

6. Emission Reduction Volumes: The Panel notes that while individual project activities are subject to review, large emission reduction projects under ACM0012 may not be extensively reviewed during registration as PoAs.