In August 2010 CDM Watch submitted a clarification request (the above mentioned AM_CLA_0191) to further improve the crediting methodology for HFC-23 abatement projects. However, although submitted in August 2010, the CDM Methodology Panel has so far not addressed the issue despite the fact that AM0001 is currently being revised.
The submissions build on the concern that the methodology does not take into account what happens when CDM HFC-23 plants are retrofitted with more efficient production techniques. Currently, such retrofitted plants continue to receive the same number of credits as they would have received without the improvements.
The issue is especially significant, since this proposal does not amend rules, it only clarifies them. That means that the CDM Watch proposal to address the improved efficiency of retrofitting would be applicable to the current crediting period of all registered HFC-23. This would directly impact credits being issued after a decision on the clarification by the Board.
Although the submission has been formally accepted by the Secretariat, CDM Watch understands that the reason why this important issue remains unaddressed is that it is not clear whether CDM Watch is qualified to file proposals under the procedural requirements.