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An open letter from civil society organizations to the COP 16 Presidency calling for the suspension of carbon credits for HFC-23 projects due to methodology flaws that lead to over-issuance. The authors urge the UNFCCC to rescind credits issued since November 26, 2010, and suggest transitioning HFC-23 management to the Montreal Protocol to ensure real emission reductions.

A coalition of NGOs argues that HFC-23 projects, which account for half of all CDM carbon credits, are based on a flawed methodology leading to the over-issuance of credits that do not represent real emission reductions. The letter criticizes the CDM Executive Board for resuming credit issuance despite these findings and calls for the rescission of credits issued since 26 November 2010, a total halt on further issuance until methodology is corrected, and the adoption of HFC phase-down measures under the Montreal Protocol.

Carbon Market Watch reports that over 800,000 Certified Emission Reductions (CERs) were issued to an HFC-23 abatement project in India on 12 November 2010, despite a suspension of HFC-23 credit issuance enacted by the Executive Board in August 2010. The organization suggests the issuance may have been an error and urges the Board to recall the credits and review the project. Additionally, CDM Watch advises potential buyers from Germany, the UK, Italy, the Netherlands, France, and Switzerland to refrain from using these credits for compliance.

Civil society organizations, including CDM Watch and EIA, sent open letters to various financial institutions and energy companies to express concerns over HFC-23 projects under the CDM. The letters argue that these projects lack environmental integrity, reward inefficient production, and create perverse incentives for the production of HCFC-22. The signatories call for changes to CDM methodology and the exclusion of these credits from the EU ETS.

The analysis finds that while the CDM enabled previously unachieved N2O emission abatement levels in adipic acid production, it also led to significant carbon leakage during the 2008 and 2009 economic downturn. It is estimated that approximately 20% of the Certified Emission Reductions (CERs) issued for these plants during that period, totaling about 13.5 MtCO2e, did not represent real emission reductions.

The document argues that the World Bank is defending HFC-23 incineration projects in China that manipulate production to maximize the generation of 'fake' carbon credits. It highlights evidence that manufacturers increase HFC-23 waste production specifically to earn Certified Emission Reductions (CERs) and criticizes the World Bank for ignoring findings from the CDM Methodologies Panel and the Montreal Protocol's TEAP. It notes that the UN CDM Executive Board has launched investigations into six such projects, including the delay of over 3 million CERs for the Changshu Zonghao project.

The document contends that HFC-23 destruction projects create perverse incentives for manufacturers to increase the production of potent greenhouse gases to profit from carbon credits. It highlights that these credits, which made up 59% of offsets used by European companies in 2009, do not support sustainable development and conflict with the goals of the UNFCCC and the Montreal Protocol.

The document examines the environmental and economic flaws of HFC-23 destruction projects within the CDM, noting that the high value of Certified Emission Reductions (CERs) encourages the production of HCFC-22 and its byproduct HFC-23. It highlights a conflict between the CDM and the Montreal Protocol, where CDM subsidies may prolong the life of older, more emissive factories. The briefing concludes that the EU should ban HFC-23 CERs from the EU ETS to redirect investment toward sustainable energy and support the Montreal Protocol's phase-out of HCFCs.

CDM Watch argues that despite mandates from decision 2/CMP.5 to improve transparency and stakeholder communication, existing Clean Development Mechanism (CDM) procedures create significant obstacles that prevent effective public participation in a manner consistent with international law and the Kyoto Protocol.

CDM Watch opposes the validation of the 'Grid connected super-critical technology based power generation in Tirora, India' project, asserting that approval would lead to the annual issuance of approximately 1.1 million Certified Emissions Reductions (CERs) that do not represent actual emissions reductions.

The Stanford Environmental Law Clinic, on behalf of CDM Watch, analyzes Project 3020's compliance with the revised ACM0013 methodology. The analysis concludes that the project is non-additional because its claimed emission reductions rely on a prohibited fuel-switching loophole (substituting domestic for imported coal). By applying conservative coal spot prices rather than the project's underestimated Indonesian coal costs, the analysis finds that supercritical technology is the most financially attractive baseline scenario, meaning the project does not meet additionality requirements.

Carbon Market Watch identifies a gap in the CDM process where public input ceases after the validation report is submitted, leaving no official way for civil society to challenge incorrect claims or trigger reviews. The submission recommends extending registration notifications to the public via mailing lists and allowing 10 UNFCCC accredited observer organisations or 100 individuals to trigger review requests to improve accountability and efficiency.

Carbon Market Watch questions the additionality of the Huaneng Wuchuan Lihanliang Phase I Wind Farm Project, citing outdated investment benchmarks and a failure to account for similar wind projects in Inner Mongolia. The statement further argues that claims regarding local employment are unsubstantiated, bird wildlife impacts are ignored, and stakeholder consultations are poorly documented.

Carbon Market Watch highlights a record increase in the number of CDM projects and CER issuances under review by the Executive Board due to the poor performance of Designated Operational Entities (DOEs). The document criticizes the current policy framework for lacking substance and proposes specific transparency measures and sanctions, including automatic suspensions and financial penalties, to ensure the integrity of carbon credits.

The document serves as a toolkit for civil society to navigate the Clean Development Mechanism (CDM) under the Kyoto Protocol. It details the seven-step project cycle—from the creation of the Project Design Document (PDD) to the issuance of Certified Emission Reductions (CERs)—and highlights specific windows for public intervention, such as the 30-day public consultation period. The guide emphasizes the importance of 'additionality' and 'baselines' to prevent the issuance of false carbon credits and explains special project categories like small-scale activities, carbon sinks (afforestation/reforestation), and Programmes of Activities (PoA).

The Clean Development Mechanism (CDM) Toolkit is a resource for civil society to navigate the complex process of carbon credit generation under the Kyoto Protocol. It details the seven-step project cycle—from the creation of the Project Design Document (PDD) to the issuance of Certified Emission Reductions (CERs)—and highlights critical technical requirements such as additionality and baseline estimation. The document emphasizes the role of Designated Operational Entities (DOEs) as validators and verifiers and outlines specific rules for small-scale, sinks, and Programme of Activities (PoA) projects. It specifically guides users on how to utilize the 30-day public comment period and other intervention points to challenge non-additional or socially harmful projects.

The research paper analyzes Germany's engagement with the Clean Development Mechanism (CDM) up to July 2009, arguing that both the global mechanism and German state policy prioritize the quantity of Certified Emission Reductions (CERs) over the quality of sustainable development. The author finds that German projects are heavily concentrated in Asia, particularly China and India, and are dominated by large-scale industrial 'end-of-pipe' projects that offer minimal sustainable development benefits. The document concludes that the German government uses the CDM primarily as a tool for economic and export promotion rather than as a means to achieve genuine climate and development goals, thereby 'abusing' the mechanism's original purpose.

The document assesses the contribution of the Clean Development Mechanism (CDM) to sustainable development in China's biogas sector. It finds that while the CDM can attract foreign investment and technology, the lack of transparent national sustainable development criteria and low incentives for CER buyers to prioritize sustainability often lead to poorly designed projects with low efficiency. The study highlights a disparity between the industrial sector, where wastewater treatment is common, and the livestock sector, which faces significant technical and financial barriers. It concludes that the CDM's second objective—advancing sustainable development—is often undermined by a 'race to the bottom' in criteria setting and a lack of international agreement on sustainability standards.

The statement opposes the PH Barro Blanco hydroelectric project by GENISA in Panama, arguing that the 258.67-hectare reservoir would destroy indigenous Ngöbe Buglé sacred sites, displace local economies based on agriculture and fishing, and increase greenhouse gas emissions through methane release from decomposing organic matter in the reservoir. It further claims the project would cause water shortages by reserving 90% of water for power generation and disrupt aquatic biodiversity and sediment flow to mangroves.

CDM Watch argues that the Clean Development Mechanism (CDM) has failed to meet its core objectives of climate change mitigation and sustainable development. The organization identifies five critical shortcomings: poor environmental integrity, minimal contribution to sustainable development, inadequate governance of the Executive Board, lack of transparency, and poor performance by Designated Operational Entities (DOEs). To rectify these, CDM Watch recommends transforming the Executive Board into a supervisory committee, delegating case decisions to a professional support structure, ensuring member impartiality and immunity, and improving documentation and observer access.