Submitting Public Comments on CDM Projects

Wednesday, October 10, 2007

The CDM project approval process allows the public to submit comments on projects applying to be registered with the CDM's Executive Board. Once a project is registered it is then eligible to be issued with carbon credits. A CDM carbon credit is called a Carbon Emission Reduction (CER). Each CER is supposedly equivalent to an avoided emission of one tonne of carbon dioxide equivalent.

Projects are open for public comments for 30 days as part of the project "validation" process. The comments are submitted to consulting companies known in the CDM jargon as Designated Operational Entities (DOEs). The DOEs, in their role as project validators, are supposed to independently audit the accuracy of the claims made by project developers. In practice the DOEs are hired by the project developers and act as their consultants, helping them to navigate the complex CDM process and receive their valuable carbon credits.

International Rivers' experience is that rather than seriously assessing public comments, the DOEs ignore or reject any questioning of the project developers' claims. Once the public comment period is closed the DOEs work with the developers to ensure their paperwork is in order, then submit a validation report as part of their "request for registration" to the Executive Board.

Public comments can also be made to the CDM's Methodology Panel on the methodologies that developers propose to use in estimating how many credits their projects will generate.

Comments submitted on specific hydro projects applying for CDM credits

Comments submitted on specific proposed CDM hydro methodologies

More information: 

Guide to the CDM and how to submit comments (in English and Spanish).