By acknowledging flaws in existing CDM crediting methodologies (such as in the case of HFC-23 CDM projects) the CDM Executive Board has made important progress. However, there is a long way to go. Many other methodologies require improvements to close loopholes to improve the CDM’s environmental integrity. This is also the case for ACM0013, the methodology for super critical coal plants.

In August 2010, CDM Watch submitted a formal request  to revise the crediting methodology for coal power plants. The submission shows that current crediting rules for new coal projects allow projects to use outdated data, not accounting for the higher efficiency of recently constructed coal-fired power plants. Surprisingly, the UNFCCC Secretariat has refused to forward this formal request by CDM Watch to the CDM Executive Board and its Methodologies Panel. CDM Watch is still waiting for the proposal to be addressed.

The current crediting rules compare the performance of new coal power plants with plants that were constructed up to ten years ago. While the original aim of the methodology was to reward only the most efficient coal plants, the current calculation of baseline emissions fails to do this. Instead it allows plant operators and project participants to claim carbon credits despite the fact that many of the projects are not more efficient and use technologies that are already common practice in the sector.

In an attempt to address this flaw, CDM Watch made an official submission to the UNFCCC proposing to adjust the crediting level to account for standard technical improvements. The proposal was due to be discussed from 25-29 October 2010 by the CDM Executive Board’s Methodologies Panel. But the UNFCCC Secretariat refused to forward it to the Methodologies Panel, arguing that it was not clear whether CDM Watch is qualified to file proposals under the procedural requirements.

In the 55^th CDM Executive Board in July 2010, the CDM Executive Board has announced it will introduce new rules on which entities are allowed to make such submissions. It requested that the Secretariat prepare a clarification on the procedures for revision of approved methodologies, clarifying the requirements regarding the nature of the entity which may submit a methodology revision. However, the Secretariat responded that it is the CDM Executive Board who has to provide clear guidance on how to proceed.

CDM Watch calls on the CDM Executive Board to: Address all formal proposals by CDM Watch as a matter of priority (including the clarification request_191 and the requested revision for ACM13) Provide clear guidance on how these concerns can be addressed in the future without unnecessary delay that undermines climate protection.