German Emissions Trading Authority

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KlimaschutzprojekteWhat are additional requirements regarding upstream emission reduction attained beginning in 2021?

076Answer

For upstream emission reductions (UER) attained beginning 2021 within an UER project activity, UER certificates may only be issued, once the verification body has confirmed to us that these UER are not offset simultaneously against nationally determined contributions (NDC) that have been assumed by the host state or by third countries in accordance with the Paris Agreement. This requirement is stated in sec. 19 (2) No. 5 of the Upstream Emission Reduction Ordinance.

To demonstrate that no double counting as stated above will occur, the lead partner could provide a confirmation by the host country, that no double counting will occur to the verification body. This confirmation (“letter of intent”) needs to be signed by the competent body of the host country, which has to be confirmed by the verification body, and fulfill the following minimal requirements:

  • Unique identification of the project activity (name, project site by longitude and latitude, lead partner, methodology)
  • Offsetting period
  • Ex ante estimate of UER to be attained by the project activity during the offsetting period of the project activity as confirmed by the validation body
  • Confirmation that emission reduction in the respective amount will not be counted towards the NDC of the host country and will not be transferred to another state for that purpose
  • Confirmation that emission reductions attained by the project activity during the offsetting period will not be approved for any other use (e.g. under CORSIA or the for the voluntary market)
  • Confirmation that all current and future requirements under the UNFCCC and the Paris Agreement will be observed regarding reporting, transparency and accounting

Please be advised that the said requirements will be amended with respect to the ongoing negotiations of the Parties to the Paris Agreements, especially regarding Art. 6.

The Letter of Intent must be submitted to us as an addendum to the first verification report concerning UER attained in 2021.

Please be advised that confirmation of the avoidance of double counting as per § 19 II Nr. 5 is not a requirement for the approval of a project activity and is will not be reviewed within the approval process. Therefore, the approval does not contain any confirmation or assurance that the requirements as per § 19 II Nr. 5 UERV are met. The confirmation of the avoidance of double counting is a requirement for the issuance of UER certificates. If the verification body cannot confirm within the verification report that there will be no double counting regarding UER attained in the project activity or such a confirmation by the verification body lacks a sufficient basis, no UER certificates may be issued even if we have approved the project activity.

10/08/2021

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