Elisa Derby
Senior Director, Climate Impacts and Standards
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Since 2022, the CCA-led Clean Cooking and Climate Consortium (4C) has led a sector-wide effort to develop a new methodology for crediting emissions reductions from cookstove projects.
The Comprehensive Lowered Emissions Assessment and Reporting (CLEAR) Methodology for Cooking Energy Transitions is the first methodology to cover all common cooking transition scenarios, eliminating the need for multiple methodologies for cookstove carbon projects. Moreover, it has been developed as a public good, available for use by any standards body or bilateral/multilateral agreement. It is intended to become the standard methodology for cookstove projects under Articles 6.2 and 6.4 of the Paris Agreement and throughout the voluntary carbon market, increasing consistency across the clean cooking carbon landscape. The CLEAR methodology incorporates the latest science on key parameters, increasing the requirements for substantiating the input parameters that have the most impact on emission reduction estimates, including mandating direct in-home measurement of fuel consumption. By using this methodology, clean cooking carbon projects will generate realistic emission reduction estimates and reduce integrity risks.
On 1 July 2024, 4C released a draft version of the CLEAR methodology and accompanying materials for public comment. The six-week commenting period concluded on August 14, 2024, during which 4C received 40 submissions comprising nearly 700 individual comments.
UPDATE FROM 11 DECEMBER 2024:
The revised CLEAR methodology has been submitted to voluntary carbon-crediting programs for review and approval. While the revised methodology and accompanying guidance documents cannot yet be published, 4C is committed to keeping stakeholders informed of key updates. Below is an overview of the key revisions made to the CLEAR methodology based on stakeholder feedback. Please note that these revisions are subject to further changes pending review by the carbon crediting programs.
“Metered” terminology adjustment
Summary of concerns: Stakeholders pointed out potential confusion/conflation between the terminology describing metered technologies (which measure energy consumption) and stove use monitors (SUMs, which measure stove use).
Methodology revision: The “metered” project category has been renamed to projects with “continuously tracked energy consumption” or CTEC projects. “Non-metered” projects are now “non-CTEC” projects. CTEC projects are those that continuously measure fuel or energy consumption directly on all project technologies through built-in or external data loggers (also known as metering), including for electric cookstoves, liquified petroleum gas (LPG), ethanol, and biogas, or through fuel sales records. Conversely, non-CTEC projects do not track all project cookstoves through energy consumption data loggers or fuel sales records.
Options to determine energy consumption in the project scenario for non-CTEC projects
Summary of concerns: Stakeholders found the survey-only and survey+SUMs approaches for non-CTEC projects overly complicated and a potential source of confusion. It was also noted that these options could disqualify CLEAR from eligibility for an ICVCM Core Carbon Principles (CCP) label. Stakeholders commented that KPTs were not sufficiently incentivized and did not adequately address any potential Hawthorne Effect.
Methodology revision: Survey-only options using CCT-derived fuel consumption ratios for determining energy consumption in the project scenario have been removed, and direct in-home measurements of fuel consumption are now required in the revised CLEAR methodology. As such, non-CTEC projects now have the following two options to determine energy consumption in the project scenario, differentiated by application (or non-application) of SUMs:
Caps and flags on allowable baseline energy consumption values derived from Kitchen Performance Test (KPT) measurements
Summary of concerns: The CLEAR methodology published for public comment included a cap on KPT-derived baseline energy consumption values for primary fuelwood users in Latin America of 0.035 TJ/capita/year (2.25 tons/capita/year of air-dried wood) and 0.0156 TJ/capita/year (1 ton/capita/year of air-dried wood) for the rest of the world. For baselines (in any region) where charcoal is the primary fuel, the cap was set at 0.0059 TJ/capita/year (0.2 tons/capita/year of charcoal). Stakeholders commented that the caps for “the rest of the world” (outside of Latin America) were too low, especially for Asia, which many suggested should have its own distinct cap, set at a value between the caps for Africa and Latin America. Some commenters noted that the baseline cap for Africa was below many current verified carbon project baselines. Some commenters proposed caps for each country.
Methodology revision: 4C decided to remove the distinction between Latin America and non-Latin American countries in the revised CLEAR methodology. Based on further review of available data, the previous cap for KPT-based baseline energy consumption estimates for primary fuelwood users has been replaced by one global cap of 0.031 TJ/capita/year (2.0 tonnes/capita/year of air-dried wood and any additional baseline fuels). Values above 0.016 TJ/capita/year (1.0 tonnes/capita/year of air-dried wood and additional baseline fuels) are flagged and require the project proponent to provide additional justification. For baselines where charcoal is the primary fuel, the cap is set at 0.012 TJ/capita/year (0.40 tonnes/capita/year of charcoal and any additional baseline fuels), and values above 0.0059 TJ/capita/year (0.20 tonnes/capita/year) are flagged for further justification. For mixed baseline scenarios (no primary fuel is used for more than 75% of cooking events) or those with other primary baseline fuels, the flags and caps are the same as those for primary charcoal baselines. When a flag threshold is surpassed, projects will have to provide justification in the Project Information Cover Sheet for why a higher baseline is realistic in that project area. For example, such justifications could include the case of households using plancha stoves or areas where wood is relatively abundant.
Evolving baselines
Summary of concerns: The CLEAR methodology published for public comment addressed two baseline concerns with a combined approach: both changes external to the project that could impact the project baseline over the course of the crediting period, and changes internal to the project that result from a mismatch between the fuel types and fuel mix proportions documented during the measured baseline and those reported by actual project households during the project monitoring. Specifically, stakeholders questioned the feasibility of the requirement for accessing and monitoring non-project households.
Methodology revision: Given the CLEAR methodology’s maximum five-year crediting period, and the fact that rapid and pervasive changes to baseline cooking practices are uncommon, the requirement to survey non-project households after the initial baseline has been removed in the revised methodology, which now permits a five-year fixed baseline.
The revised CLEAR methodology still addresses potential over-crediting resulting from a mismatch between the fuel types, fuel mix proportions, and household sizes documented during the baseline scenario and those reported by actual project households during the project monitoring, relying on retrospective questions of project households applied during the first usage survey. Where a material discrepancy is revealed, project proponents must either remove participants who do not conform to the baseline profile from the project or follow guidance provided on adjusting the baseline (toward lower baseline emissions). If no mismatch is identified, the baseline shall be recalculated at the start of each crediting period (every 5 years at a maximum).
Definitions of user and associated terms and caps
Summary of concerns: Many stakeholders requested explicit guidance to determine the criteria for defining ‘use’ vs ‘non-use’. Stakeholders also noted that terms related to stove usage were not clearly defined.
Methodology revision: Requirements for what constitutes a user have been included in the updated version of the CLEAR methodology. Related terms have also been revised for clarity:
Using these concepts, the revised methodology includes caps on the number of PTDs based on whether the project provides customer support actions. For a non-CTEC project to be eligible to claim up to 90% of maximum PTDs, the project proponent must take the following customer support actions and provide details of how each condition has or will be met on the Project Information Cover Sheet during the design phase of the project.
Project proponents who do not undertake all three of these customer support actions may claim up to 75% of maximum PTDs.
Additionality
Summary of concerns: The CLEAR methodology published for public comment stipulated only one additionality test, which was a common practice analysis, with a ceiling of 20% market penetration of the project technology. We received comments suggesting other forms of additionality tests were important and/or better aligned with individual projects, as well as comments suggesting the 20% ceiling was both too high and too low. Further, UNFCCC is currently developing the additionality tools, rules, and guidance for Article 6 implementation, which we expect voluntary carbon-crediting programs to adopt.
Methodology revision: Instead of requiring any particular additionality approach(es), the revised CLEAR methodology includes language requiring projects to follow the additionality requirements mandated by the carbon-crediting program under which the project seeks to issue credits using the CLEAR methodology (whether that is a market penetration check, barrier analysis, etc.). In the case that the carbon-crediting program does not already require consideration of parallel sources of funding for cooking energy transitions (e.g., overseas development assistance, other subsidies) available within the project boundary, the demonstration of additionality further must list and describe such sources of funding and explain why they do not apply to the project activity. If they do apply, they must be considered in the demonstration that the project activity would have not occurred in the absence of the support of revenues from the carbon credit sales.
4C may suggest further revisions to the CLEAR methodology’s additionality section if expected UNFCCC/VCM guidance is not forthcoming.
Applicability to institutional and/or commercial cooking
Summary of concerns: Stakeholders requested that the methodology apply to institutional and/or commercial cooking energy transition projects.
Methodology revision: The revised methodology applies to and provides guidance for institutional cooking and CTEC commercial projects.
Applicability to biogas projects
Methodology revision: The revised CLEAR methodology is only applicable to biogas projects that use a continuously tracked energy consumption (CTEC) approach.
Additional requirements for artisanal stoves
Summary of concerns: Stakeholders noted that artisanal stoves have wide variability in performance and thermal efficiency and as such, the CLEAR methodology should tighten applicability criteria for artisanal stoves.
Methodology revision: The revised CLEAR methodology requires that for artisanal cookstoves, at least three randomly-selected samples of each cookstove model must be used when testing for ISO thermal efficiency, and when undertaking CCTs.
Seasonality
Summary of concerns: Stakeholders noted that the guidance for addressing seasonal variation in fuel consumption patterns was vague.
Methodology revision: The revised CLEAR methodology requires that prior to project validation, projects must collect data during the baseline scenario survey on the relative fuel use at different times of the year. Project proponents are required to incorporate the resulting information into their monitoring plan design and to justify on the Project Information Cover Sheet how the approach they are taking will result in accurate baseline and project fuel use measurements. If space heating is common in the project area, the justification must include an explanation of how space heating has been addressed in the project design. If an accurate approach cannot be taken, then the project proponent must instead select and justify a conservative approach.
Inclusion of transportation in upstream emissions
Summary of concerns: Stakeholders noted that upstream emissions should account for transportation, as emissions due to transportation of certain fuels like LPG may be material.
Methodology revision: In the revised methodology upstream emissions now include transportation of fuels (except for electricity where it is accounted for in a separate parameter).
Marginal fNRB
Summary of concerns: Stakeholders noted fNRB would be more accurately measured as a marginal quantity rather than an average. Currently, fNRB is calculated as a national average, assessing the balance between how much wood is harvested and how much it regrows under standard conditions, over several years. A marginal approach to fNRB would focus on the change in woodfuel renewability due to the specific change a project makes in wood harvesting. .
Methodology revision: MoFuSS developers are currently exploring the implications of using a marginal approach to estimating fNRB. The revised methodology notes that if UNFCCC determines that a marginal approach to calculating fNRB is allowable, MoFuSS may be used to calculate marginal fNRB for a given project under the CLEAR methodology.
CLEAR accompanying guidance documents
Methodology revision: The revised CLEAR methodology has various appendices, which include requirements and best practices for sample design, surveys, KPTs, CCTs, and SUMs, as well as guidance on how to apply CLEAR to eligible commercial and institutional projects.
Archive
Here are the versions of the draft CLEAR Methodology, accompanying calculator tool, and Explanation of Decisions document that were subject to public comments.
These are now outdated versions. Final versions that have been revised, as described above, will be linked here once published by carbon crediting programs.