be effectively submitted as individual CDM projects, and micro technologies such as light bulbs and cooking stoves now have the option of being registered as organized programs of activities under the current CDM. The fact is, most developing countries do not _need_ (and may not want) any other set of rules in order to supply their mitigation potential into the market. Small or least developed countries often do not have either the institutional ability to put in place complicated GHG accounting schemes, nor the eagerness to be distracted from more urgent development challenges. However, it is clear that in order to scale up mitigation in the larger emerging economies we must go beyond current CDM practices; this will be discussed below. Here we only emphasize that whether Parties decide to enhance the CDM post 2012 or to create another complementary market instrument, the option to participate in the offset market with activity-based projects will probably not be retracted.

This is not to say that the CDM is a finished product. It is painfully evident that in order to deal with the high volumes of projects already in the system, it should incorporate several key administrative improvements and the sooner the better. In the following we list (i) measures that could be undertaken directly by the EB without changing the Marrakesh Accords and without the need for a COP/MOP decision, (ii) improvements of the CDM requiring a COP/MOP decision that revises the Marrakesh Accords without touching the fundamental principles of the CDM. Any changes undertaken by the EB for the first commitment period would presumably stay in place after 2012, while reforms that require a more profound reform of the CDM would likely only take effect in 2013.

# (I) <u>Improvements that can be enacted by the Executive Board itself</u>

- **Delegation to the Secretariat.** Assuming that the level of CDM submissions continues to rise and that nominations to the Board will, at least for the next three years, continue the current practice of part-time Board members who volunteer their time and do not have regulatory experience, it is inevitable that the Board delegate even more responsibility to the Secretariat than it has in the past.  Over the past 2-3 years the Secretariat has been adding and training staff to support the various functions of the EB. This trend will probably continue. One specific task that could be delegated to the Secretariat relates to issues where clear guidance from the EB is available and yet not complied with in Project Design Documents (PDDs).  Without triggering a request for review, the Secretariat could request these corrections as part of its completeness check, thus significantly decreasing the high volumes of requests for review.<sup>35</sup> Of course there are issues where EB guidance is not so clear and which need to be considered by the EB in its role of policy definition. The ultimate responsibility will certainly continue to reside with the Board, but project review could be shifted even further to the Secretariat, avoiding unnecessary delays and allowing the EB to focus more on policy decisions.

> 35 An analysis of all requests for review between EB32 and EB42 shows that 430 out of 750 questions from the EB to the DOEs are merely clarification requests. The procedure to request a review has thus been mis-used in over 50% for simple requests for clarification.

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