"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.