The Consultation Process

The Verified Carbon Standard (VCS) Program is a standard and framework for GHG emission reductions and removals. On 1 September 2011, VCS released for public consultation draft requirements for standardized approaches for baselines and additionality.

The consultation is open until 30 October 2011 at 6pm US EDT. Comments are invited and should be sent to secretariat@v-c-s.org.

VCS will review all comments, revise the draft requirements as needed and present final requirements to the VCS Board. The final requirements are expected to be ready for release in early 2012.

Overview of the Draft Requirements

Performance methods set performance benchmarks, or metrics, for determining additionality and/or the crediting baseline. Project activities that meet or exceed a pre-determined level of the performance metric (for example, a given level of CO₂e emissions per unit of output) may be considered additional, provided they also meet other qualifying criteria. A performance benchmark can also serve as a baseline for crediting GHG emission reductions and removals.

Activity methods use a positive list to pre-determine additionality for given classes of activities. Project activities may qualify for a positive list if they are not financially viable without carbon finance, have no revenue streams other than carbon finance, or have low rates of adoption in the marketplace. An activity that qualifies for a positive list is automatically deemed to be additional.

VCS Director of Program Development Jerry Seager and Steering Committee Chair Michael Lehmann (Director of Services and Technologies, DNV Climate Change Services) hosted a webinar on 13 September to describe the standardized methods. Watch the webinar or download the presentation (if you have trouble viewing the webinar, click here).

Where to Find the Draft Requirements

The draft requirements are incorporated directly into three VCS Program documents and highlighted in red:

1)  VCS Standard. Most of the draft requirements are in the Methodology Requirements section of the VCS Standard. Specific requirements are set out in each sub-section, covering issues such as those relating to data requirements, determination of performance benchmark levels, criteria and procedures for establishing positive lists, applicability conditions for standardized methods, and other aspects relating to baselines and additionality. Some requirements relate to all standardized methods, while others relate specifically to performance methods or activity methods. New methodology elements using standardized methods must follow these requirements, and validation/verification bodies must assess new methodology elements against them. Some requirements are set out in the Project Requirements section. These tell projects how to use methodology elements that apply standardized methods.[2]

2) Methodology Approval Process. Draft requirements in Section 9 of this document (Use of Experts in the Assessment of Methodology Elements) state that a VCS-approved expert will be used to assess new methodology elements that apply standardized methods. A new section – Section 10 – outlines the procedure for periodic review of approved methodology elements that apply standardized methods.

3) Program Definitions. Some new definitions relevant to standardized methods have been provided to accompany the new requirements for standardized methods.

In addition to the draft requirements in red, general guidance appears in gray “Rationale” sections. These sections provide background to help readers interpret the requirements. After the consultation, this information will be moved into a standalone guidance document.

Consultation on the Draft Requirements

Stakeholders are encouraged to review and reflect on the draft requirements as a whole and to provide feedback on any and all issues. In addition, VCS welcomes specific feedback on the following questions:

1)     Are the draft requirements both workable and sufficient in their provision of environmental safeguards? The requirements should ensure environmental integrity but also be practical for methodology developers.

2)     Are the draft requirements likely to deliver the expected results for the types of projects with which you are most familiar? For example, there are certain types of projects one intuitively feels should qualify for a positive list and others that should not, so do the draft requirements deliver the expected outcome? Likewise, do the specifications for performance methods lend themselves to the project activities one feels could be addressed via performance benchmark approaches?

3)     Are the requirements with respect to setting the level of the performance benchmark metric sufficient? Should more detail be provided to ensure methodologies set an appropriate level, either initially or through on-going post-approval assessment? Are requirements sufficient in relation to the frequency and procedure by which standardized methods must be updated?

4)     Does the financial viability specification (Option B under activity method) provide a procedure by which classes of project activities can reliably and consistently be deemed as additional? Are the extra specifications on applying the CDM additionality tool sufficient to establish additionality for an entire class of project activity (noting that the tool was designed for demonstrating and assessing additionality for individual projects)?

5)     Are the draft requirements sufficiently clear to ensure correct and consistent interpretation?

Future Work

The draft requirements are the first round of deliverables from the Steering Committee on Standardized Approaches to Baselines and Additionality. The committee will continue its work through 2012. VCS is grateful to all committee members for their hard work and commitment.