Issues (conŐt)
"Double-Counting – in the case of this project, no one should be able to claim credit from buying a new AC unit – whether its retailers, distributors or individuals.  Ghana DNA can enforce through approval process.
"Free Riders: Could be a problem with other types of programmatic CDM (eg: a voluntary EE program).  The mandatory standards avoids that problem by making only one entity – the Government Energy Regulator – the sole holder of CERs.
"Leakage: No additional leakage should occur in this case but again, could be an issue in other types of policy-CDM programs.
"Decision http://unfccc.int/meetings/cop_11/items/3394.php in the document called "Further guidance relating to the clean development mechanism", para. 20.  now clears the way for programmatic CDM