EB65 Annex 3 paragraph 14 placed an obligation to coordinating managing entities
(CME) to provide inclusion criteria for a CPA in the PoA.
These obligations are further clarified in the document in paragraphs 15 and 17.
The extensive requirements in effect turn the CME into a DOE in terms of inclusion of a CPA, with the CPA operating having to in effect provide the CME with the application of the CME process for inclusion of the CPA.
Problem is many PoA have been registered without these inclusion criteria. In the absence of these EITG suggests that it is almost impossible for a CME to include a CPA without that CPA being fully validated by the DOE.
The intention of course is the CME takes the role of the DOE and ‘validates’ the CPA before asking the DOE for inclusion.
Most DOE see the inclusion process as simple and quote significantly less to include a CPA. However with PoA registered before EB65 was released it appears their inclusion criteria are so weak and subjective that a DOE will be forced to validate the CPA itself!
It will be interesting to see what happens in practice as new CPA are introduced. The rush to register PoA prior to the end of 2012 to allow those CPA under the PoA continued access to the EUETS seems to be the start of issues for CME and their DOE.