Convoluted UN rules. Made for corrupt and bad policies
Additionality: defined as emissions reduced as below those that would have occurred in the absence of registered CDM activity.
Result of this is convoluted and expensive methodologies to establish that project is additional.
Result is creative accounting (read corruption)
If government has law to mandate lower emissions, then project will not qualify for CDM
Result is perverse incentives to governments not to do anything.
Kyoto baselines: Protocol is based on taking emission reductions over current (or specified year baseline).
Cheap options are in the highest end of baseline. No incentive to governments to reduce emissions.