Application of PACM baseline rules – an Improved Cookstoves case study submitted to The Article 6.4 Supervisory Body and Methodology Expert Panel on October 3rd 2025 in a joint letter with IETA. This case study includes the findings from the first in a planned series of analyses undertaken by the Project Developer Forum applying the methodological requirements under the Paris Agreement Crediting Mechanism (PACM).
Background
To better understand the practical implications of PACM requirements, the Project Developer Forum members applied the PACM baseline rules to an improved cookstove project.
Our analysis shows that newer cookstove methodologies already apply conservative parameters (including, for example, fNRB, stove efficiency, and emission factors). The PACM rules impose further structural adjustments to ensure conservativeness. In our test case, applying PACM adjustments on top of already conservative parameters reduces credit volumes by approximately 27% compared to conservative market practice.
Recommendations for consideration
Based on the Project Developer Forum analysis, we respectfully request that the PACM Supervisory Body and Methodology Expert Panel consider the following approaches to ensure methodological accuracy:
1. Over-correction risk analysis: Assess the cumulative impact of all adjustments towards a conservative baseline setting, to consider the risk of over-correction.
2. Accuracy over conservativeness: Allow well-justified deviations from the baseline standard’s stepwise baseline determination and default adjustments - to ensure credits reflect actual project performance.
3. Sector and regional specificity: Recognise and facilitate the development of robust sectoral or national values or defaults, where such data is available.
4. Proportionate flexibility: Incorporate proportionate flexibility for small-scale activities or data-constrained contexts, including developing countries that require the flexibility, Least Developed Countries and Small Island Developing States, while maintaining environmental integrity.