Issues Raised
"Ownership of CERs – who owns the credits
for such a dispersed
project? Proposal in this case:
GhanaÕs Energy Commission
– The Energy Regulator
"Additionality – need to show that the
policy itself could not be implemented without CDM. This is possible in the case of Ghana but may be tricky in other
cases. May require an additional level of proof by the
project developer beyond the current additionality test tool.
"Monitoring: Methodology requires sampling
of key variables (hours
of use, etc.). Method proposes
sampling to a margin of error of less than 5% -- then discounting ERs by the margin
of error to be
conservative. Sampling is allowed
in CDM.