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Standard on Avoidance of Double Counting V1.0 - 2022 Global Carbon Council Standard on Avoidance of Double Counting 2 of 14 Global Carbon Council Standard on Avoidance of Double Counting 3 of 14 Contents 1. INTRODUCTION 5 2. SCOPE AND APPLICABILITY 6 3. REQUIREMENTS 6 3.1. EXISTING REQUIREMENTS IN OTHER GCC PROGRAM DOCUMENTS 6 3.2. ADDITIONAL REQUIREMENTS 8 3.2.1. HOST COUNTRY LETTER OF AUTHORIZATION HCLOA 8 3.3. TIME OF SUBMISSION OF HCLOA 9 4. CONSEQUENCES AND LIABILITY OF DOUBLE CLAIMING 9 APPENDIX DRAFT TEMPLATE- HOST COUNTRY LETTER OF AUTHORIZATION HCLOA 10 Global Carbon Council Standard on Avoidance of Double Counting 4 of 14 ACRONYMS ACC Approved Carbon Credit CDM Clean Development Mechanism CORSIA Carbon Offsetting b double use - which occurs when the same issued unit is used twice, for example, if a unit is duplicated in registries; and c double claiming - Double claiming, which occurs if the same emissions reduction is counted twice by both the buyer and the seller i.e., counted towards the climate change mitigation effort of both a buyer and the host country of the emissions reduction activity. In order to prevent double claiming, eligible programs should require and demonstrate that host countries of emissions reduction activities agree to account for any offset units issued as a result of those activities such that double claiming does not occur between the buyer and the host country of the emissions reduction activity.” 4. Double issuance as referred in paragraph 3a above and Double use or double sell as referred in paragraph 3b above are already addressed in existing GCC Program’s requirement as contained in the GCC Program Manual5 section 10.26. 1 https//unfccc.int/sites/default/files/resource/cma3_auv_12a_PA_6.2.pdf 2https//americancarbonregistry.org/carbon-accounting/guidance-tools-templates/guidelines-for-adc-with-corsia-june- 2019.pdf 3 https//www.icao.int/environmental-protection/CORSIA/Pages/default.aspx 4 https//www.icao.int/environmental-protection/CORSIA/Documents/ICAO_Document_09.pdf 5 https//www.globalcarboncouncil.com/resources/GCC-Program-Manual-v3.pdf 6 In addition to Program Manual provisions, it is the responsibility of project owner to check from IHS Markit Meta registry that there is no double issuance and double use of issued carbon credits by GCC Program. Global Carbon Council Standard on Avoidance of Double Counting 6 of 14 5. Double claiming as referred in paragraph 3a above has been partially dealt with existing GCC Program’s requirement as contained in a Project Standard7 refer to paragraph 25 and 14 c, v; and b Project Submission Form8 PSF template refer section A.6 and the instructions therein on page 42. Through this document GCC Program introduces additional requirements and procedure for GCC projects to demonstrate project registration and issuance level compliance with Article 6.2 of Paris Agreement and CORSIA Emissions Unit Eligibility Criteria concerning double claiming, as referred in paragraph 3c above. 2. SCOPE AND APPLICABILITY 6. This document addresses the of avoidance of double claiming as referred in paragraph 3c above in line with the requirements of the CORSIA scheme as well as that of article 6.2. This document applies to GCC projects that voluntarily seeks C or CA market eligibility flags of GCC at the time of registration and/or at the time of issuance of Approved Carbon Credits ACCs issued by GCC. 7. C is the market eligibility flag denoting that carbon credit is eligible for the use towards meeting carbon neutral growth target of an international airline committed under CORSIA. CA is the market eligibility flag denoting that the carbon credit is eligible to be used for other purposes other than international mitigation purposes of CORSIA or recipient country’s NDC target compliance such as voluntary carbon markets offsetting purposes, where the buyer requires that the issued carbon credit will be included in the corresponding adjustments towards host country NDC target. 8. This document is intended to be used by all stakeholders including Project Owners, GCC Verifiers, the GCC Operations Team and the GCC Steering Committee and shall be read in conjunction with Project Standard, Verification Standard and PSF template and instructions therein and other applicable GCC documents. 3. REQUIREMENTS 3.1. Existing requirements in other GCC Program documents 9. Project Standard refer to paragraph 14, c, v requires Projects Owners to comply with the GCC Rules related to submission of Host Country Attestation Host Country Letter of Authorization HCLOA on Double Counting9 as and when required by CORSIA mandatory requirement for projects that intend to use ACCs for offsetting by airlines for CORSIA compliance10. 10. Project Standard refer to paragraph 25 requires projects to use the latest versions of the Project Submission Form PSF template to provide information on demonstration of the avoidance of double counting to ensure that the offsets are only counted once towards a mitigation obligation refer section A.6 of PSF template and section A.6. page 42 of the instructions therein. Global Carbon Council Standard on Avoidance of Double Counting 7 of 14 11. PSF template refer section A.6 requires to demonstrate the compliance with the CORSIA requirements of avoidance of double counting on project-to-project basis and requires Project Owners to obtain and provide to the GCC Program and its Registry IHS Markit, a written host country attestation or HCLOA from the host country’s national focal point or focal point’s designee, as required by CORSIA Emissions Unit Criteria paragraph 7 c of Carbon Offset Credit Integrity Assessment Criteria and ‘Programme Application Form – Appendix A – Supplementary Information Form’11 refer section 3.7.8. with respect to- Host country attestation to the avoidance of double-claiming. This HCLOA shall be made publicly available prior to the use of units from the host country in the CORSIA. Therefore, the onus lies on the Project Owner to comply with this requirement. The handover of HCLOA by Project Owner to GCC Program for the avoidance of double claiming is a pre-requisite for use of the emission units for offsetting under CORSIA12. Without such HCLOA, GCC Program will not flag the emission units generated from the projects as ‘CORSIA compliant’ in the registry. This will ensure that offsets from GCC Projects are only counted once towards a mitigation obligation. 12. The overall GCC process for requiring HCLOA for issuance of market eligibility flags for the avoidance of double accounting of ACCs in the global context of Article 6.2 of Paris Agreement are depicted in figure-1 below. Figure-1 Process of issuance of market eligibility flags for avoidance of double accounting 11 Available at https//www.icao.int/environmental-protection/CORSIA/Pages/TAB.aspx 12 Based on COP26 decision -/CMA.3 on Article 6.2, this pre-requisite will be applicable for all units for which host HCLOA is issued and not only CORSIA units. Global Carbon Council Standard on Avoidance of Double Counting 8 of 14 3.2. Additional Requirements 13. Project Owners seeking GCC approval for eligiblility of issued ACCs for market eligibility flags shall provide the following information, in addition to that quoted in section 3.1 above 3.2.1. Host Country Letter of Authorization HCLOA 14. Project shall provide a ‘HCLOA13’ from the designated national authority or designated focal point of the host country of the project activity where the project is located. The template for HCLOA is provided in Annexure 1 and 2 of Appendix. At minimum, HCLOA shall a Include the GCC project unique identification details – Submission number SXXX14, IHS Markit Project Id15 if available, Name of the host country where the project is located, and Title of the Project Activity; b Include the weblink of GCC Project website and GCC public Registry on IHS Markit public registry where the project is publicly available; c Shall authorise the Project Owners, with the contact details and the authorised representative, as per the Annex 1 of the Project Submission Form PSF; d Acknowledge that the project activity is likely to reduce emissions in the host country; e Acknowledge that the GCC Program to which the letter is provided has issued, or intends to issue, offset credits for the emission reductions that occur within the country; f Authorize the use of the emission reductions, issued as offset credits to project, by user in order to meet offsetting requirements of either CORSIA or article 6.2 or voluntary buyers requiring the corresponding adjustments to be applied by host country; g Declare that the host country will not use the project’s emission reductions to track progress towards, or for demonstrating achievement of its NDC and will account for their use for either international mitigation purposes or other purposes, by applying corresponding adjustments in section B of Annex 1 of COP26 decision - /CMA.3 on Article 6.2. h Signature and contact details of authorised signatory of designated national authority or designated focal point of the host country. 13 The draft template for Letter of Assurance and Authorization LOAA provided in Annexure 2, aims to provide high level guidance on such letter and the countries may wish to use this. 14 Refer paragraph 19 of Program Process 15 Refer paragraph 56 of Program Process Global Carbon Council Standard on Avoidance of Double Counting 9 of 14 3.3. Time of Submission of HCLOA 15. Paragraph 33d of Program Processes document requires Project Owners to submit the HCLOA16 together with the project documentation required for submission of request for registration17 of the project with the GCC Program to allow GCC Project Verifier to conduct verification18 before the GCC project activity can be displayed as having market eligibility flag C or CA’ on the GCC Project website19 and GCC registry. 16. Notwithstanding to the document submission requirement mentioned in paragraph 15, if the above documents cannot be submitted by the Project Owner as part of request for registration, then, HCLOA for the project activity shall be submitted to GCC Program together with the project documentation required for submission of request for issuance20. If Project Owner cannot provide necessary HCLOA at project registration stage however makes a declaration in Project Submission Form that such letter shall be submitted at the stage of request for issuance. GCC Program can issue market eligibility flag at the request for registration stage based on declaration of Project Owner, however such market flag merely represent the Project Owner’s intentions. For issuance of any of these market eligibility flags at the ACC issuance stage, the HCLOA must be submitted by Project Owner at the time of submission of request for issuance. If the host country grants HCLOA for entire crediting period of project and commits to apply corresponding adjustments throughout, there is no need for issuance specific HCLOA. However, country may choose to issue the issuance specific HCLOA. 4. CONSEQUENCES AND LIABILITY OF DOUBLE CLAIMING 17. As per COP26 decision on Article 6.2, it is the host country’s responsibility to ensure that no double claiming is done under NDCs for the emission reductions from the GCC registered projects for which the host country has provided the HCLOA to GCC. If the HCLOA is issued at the stage of specific issuance, the host country must ensure that no emission reductions from the corresponding monitoring period of project are claimed under NDC. 18. All the reporting requirements annual and regular as per section IV B and IVD of Annex to Article 6.2 decision21 are applicable to the host country. 19. GCC Program will transparently provide to relevant authorities and registries the information on no. of credits issued for different monitoring periods for different projects along with the market eligibility labels C, CA for which authorization letters are received from host countries. However, GCC Program shall have no liability towards ensuring that host country has not claimed the emission reductions corresponding to issued ACCs under its NDC. 16 HCLOA is also called as ‘Host Country Attestation on Double Counting’ as mentioned in paragraph 33d of Program Process https//www.globalcarboncouncil.com/resources/GCC-Program-Processes-v3.pdf 17 Refer paragraph 33 of Program Process 18 Refer paragraph 29 of Program Process Global Carbon Council Standard on Avoidance of Double Counting 10 of 14 Appendix DRAFT TEMPLATE- HOST COUNTRY LETTER OF AUTHORIZATION HCLOA The draft templates for Host Country Letter of Authorization HCLOA included in Annexure 1 and 2, aims to provide guidance and the host countries of GCC project may wish to use this. Project Owners shall provide HCLOA prior to submission of request for registration and/or each request for Issuance to GCC Program. The Host Countries should provide the details, either using the template given below or in their own template, and get it signed off from the authorized signatory of the Host Country. 19 Refer paragraph 51 of Program Process 20 Refer paragraph 72 of Program Process 21 https//unfccc.int/sites/default/files/resource/cma3_auv_12a_PA_6.2.pdf Global Carbon Council Standard on Avoidance of Double Counting 11 of 14 Annexure-1 Template for HCLOA to be submitted at the time of request for registration authorizing the mitigation outcomes of the project over entire crediting period of ten years Ref. [Date] Sub Host Country Letter of Authorization of Project Activity [“Title of the Project Activity”] and the Program titled “Global Carbon Council GCC” Dear [ “Name of the Project Owners22”], Dear [ “Global Carbon Council GCC Program”], On behalf of the Government of [Name of Country], I have the pleasure to inform you that [“Title of the Project Activity”] with project ID [serial number of Project Submission number SXXXX23, submitted to “[GLOBAL CARBON COUNCIL GCC]” is authorized as a mitigation activity whose mitigation outcomes over the entire crediting period of ten years can be used, following provisions of Article 6.2 of the Paris Agreement, for the purpose of [compliance of Nationally Determined Contribution of [name of country]] [mitigation purposes under CORSIA] [offsetting the emissions of voluntary carbon credit buyers]. The Government of [Name of Country] confirms that a [Name of Country] has ratified the Paris Agreement on [Date] and submitted its latest no of the NDC Nationally Determined Contribution NDC on DDMMYYYY to the UNFCCC; b The issued Mitigation Outcomes under the Project shall not be used by the Government of [Name of Country] to demonstrate achievement of its own NDC; c The Project contributes to sustainable developmen
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