To The CDM Executive Board, Public call for input reg. Type II SSC. Methodologies

To the CDM Executive Board: Public call for input reg. Type II SSC. Methodologies
LEQUAN Minh Cuong, GERES, Pnom Penh, Cambodia, August 13, 2006

Submitted to the Small Scale CDM Call for Public Inputs on Barriers to Developing Energy Efficiency Projects

Respected Sirs and Madams,

Greetings from Cambodia.
GERES is an environmental NGO aiming at social and economic development. We are involved in Cambodia in the dissemination programs of energy efficient stoves, for domestic cooking and thermal applications in decentralized small units (family to SME scale).

As numbers are large and monitoring well developed, we have been looking since 2004 at Carbon Finance to provide much needed resources: Voluntary Market (www.co2solidaire.org is the first French-speaking portal for Carbon Offsets) and CDM with Type II methodologies.

The CDM pipeline is still closed to stove projects at the methodology level. Different groups work on I.E and II.C. In our case, we would like II.G. modified as follows.

A. Remove –or at least significantly increase- the 45 GWh ceiling for biomass stoves. This would allow enough numbers of stoves to setup a project.

B. Remove the reference to fossil fuels in ER calculations.
a. whatever the source of energy -renewable or not- it should be used efficiently: this reference to fossil fuels is irrelevant.
b. it unfairly reduces by 40% the emission reductions our projects could claim. Combined with a small ceiling (comment A), the bankable ERs would only serve to pay consultants and transaction costs.

C. "Sustainable development" has been valued in countless but empty statements. For stove projects in LDCs, that undoubtedly demonstrate livelihood improvements, leakage should be discarded (in the form II.G. was first submitted by the SSC Meth. Panel).

Sincerely,
LEQUAN Minh Cuong (Mr)
Program Officer

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See also submissions regarding stoves and firewood by

CEDESOL

HEDON

Chris Adam

World Bank

Øko-net (Eco-Net)Denmark

REAP Canada

Eco-Securities UK