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Public participation improvements on the horizon (Newsletter #14)

If the CDM is to strengthen its reputation and the quality of its projects, it has to act swiftly and decisively in excluding problematic projects. Further safeguards have to be put in place to ensure such projects do not enter the CDM pipeline. Improved public participation infrastructures could go a long way to help flag and weed out such ‘bad apples.’

Several CDM projects (such as in Honduras, Panama and Colombia) that have violated public participation rights have caused an outcry from civil society organisations. There is widespread dismay that public participation in the CDM is not taken seriously.

Stringent public participation rules and clear guidance would allow for early detection of non-conformities in the CDM process. This would also help to filter out sub-standard projects at an early stage in the CDM project cycle.

The right to information, the right to public participation and the right to seek justice are basic human rights. Transparency, accountability, and integrity are integral components of an effective governance system, in particular, where public resources and decision making processes impact on human rights and sustainable development.

Principle 10 of the 1992 Rio Declaration on Environment and Development was agreed on at the UN Conference on Environment and Development:

Environmental issues are best handled with the participation of all concerned citizens, at the relevant level. At the national level, each individual shall have appropriate access to information concerning the environment that is held by public authorities,…, and the opportunity to participate in decision-making processes. States shall facilitate and encourage public awareness and participation by making information widely available. Effective access to judicial and administrative proceedings, including redress and remedy, shall be provided.”

On the basis of the main obstacles in the CDM participation process, CDM Watch has continued to recommend the following improvements over the past years:

CDM Watch recommendations for improved public participation:

  • Set up email notification systems for registration, issuance and methodology processes as well as for all public participation procedures that are time-limited
  • Improve the user-friendliness of the UNFCCC CDM website and translate it into all official UN working languages
  • Make essential documents of CDM projects available (at least the PDD and the EIA) in the language(s) of the host country
  • Make hard copies available of the translated PDD to affected communities
  • Ensure that all supporting documents are uploaded prior to the public commenting period
  • Allow submissions of comments in the language(s) of the host country
  • Allow delayed submissions of comments if the delay is due to a reasonable justification
  • Increase the length of the public commenting period for large projects
  • Increase the length of the public commenting period for new methodologies
  • Create a mechanism so that concerns about CDM projects can be submitted at any time.

CDM Watch very much welcomes the discussion of this issue at the upcoming CDM Executive Board meeting starting on 30 May 2011. The box below summarizes the points that are on the meeting agenda:

Issues listed on the agenda of the upcoming CDM Executive Board meeting:

  • The Board to open public consultation on the improvement and further specification of public participation requirements
  • The Secretariat to consider developing a listserve to inform potential stakeholders of upcoming commenting periods for CDM projects, as well as other calls for input on different matters
  • The Board to seek further guidance on the local and global stakeholder consultation procedures, to be inserted as appropriate in future versions of the Validation and Verification Standard
  • The Board to encourage the DOE Forum to address the issue of best practice in promotion of stakeholder involvement, by possibly publishing sets of examples or best practice guidance in validation of such requirement
  • The Board to consider, in a further revision to its review procedures, the possibility of opening an early period of potential consultation with project proponents and other stakeholders on the ground for review, based on the initial assessment by the Secretariat
  • Translating CDM documentation into the six official UN languages


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