This is of concern to developers, as the process is increasingly considered as tedious and highly uncertain. As such, the process discourages project developers from applying for such investments. Furthermore, EE projects that end up generating CERs are mostly from the large industrial sector, not in end-use energy efficiency, a sector that remains largely untapped. Kyoto Protocol Article 12 paragraph 5.c. For more information on this issue please refer to Buchner, B. and P. de T'Serdaes, "How to trigger energy efficiency: The case for carbon finance?" ( The complexities of the CDM approval process only increases the complexity and uncertainty of EE financing and result in higher transaction costs for project developers.