In addition to the evidence that was filed in March 2010 related to the gaming of the CDM by unscrupulous plant operators, CDM Watch has submitted a request to clarify current crediting rules for HFC-23 abatement projects. This new submission AM_CLA_0191 seeks to clarify how the waste generation rate should be calculated for HCFC-22 production plants where key components have been replaced or retrofitted. The introduction of more efficient production techniques would logically lead to the reduction of the baseline waste generation rate but the wording of the methodology is unclear on this point. The request was first discussed at the Methodologies Panel meeting from 25-29 October 2010. However, the Meth Panel failed to adopt a specific recommendation to the Board.
Action to be taken by the Board:
As the methodology AM0001 is on hold and being revised in the coming months, Board members should urge the Meth Panel to come forward with a clear recommendation including the concerns highlighted in the clarification request. However, while a revised methodology will only apply to new crediting periods, such a clarification would already impact the current crediting period. The introduction of more efficient production techniques could lead to fewer emissions compared to the baseline. However, this possibility is not currently reflected in the baseline, which is leading to excess issuance of credits. At a time when the integrity of the CDM is being called into question for a number of reasons, the Board should make immediate changes where possible to safeguard environmental integrity.