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Since Kyoto was ratified by Russia back in 2005, we have seen the EB become a second operational entity that double checks each small tasks that DOEs do. This implies that the EB doesn't rely on DOEs to perform the job. Why then create DOEs if the EB redoes the work.

Wouldn´t it be better to follow Voluntary Carbon Standard (VCS)'s approach which relies significantly more in independent entities while the registering body only does spot checks ?

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  1. Auditor oversight is existing even in the financial sector, although red flags there do not seem to recently have been what they used to be ;-).
  2. DOE rejection rates are still far above EB rejection rates.
  3. EB reviews are only desk reviews, mostly for consistency. DOEs suffer from extremely rapid expansion and therefore quality problems. Quality control from the EB is still quite necessary. It will, hopefully, become less so in the future. Ideas for solutions?
  4. If inconsistencies become too many, the EB can and does perform spot checks.
  5. DOEs are paid by project owners; if they cause too much trouble, i.e. if they do their work properly, they are threatened to be replaced by another DOE. So they need support from the EB in the form of rejections in order to justify good work towards project owners.
  6. Has any DOE in the VCS actually faced spot checks until today?
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