Implications of ACM0013 on GHG Emission Reductions through grid connected high efficiency power generation

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.

• The CDM Executive Board revised the ACM0013 methodology to eliminate a loophole that allowed project participants to claim emission reductions by substituting fuels within the same category, such as replacing imported coal with domestic coal.
• Project 3020 is considered non-additional under the revised ACM0013 because its additionality depends on switching domestic for imported coal; once these differences are neutralized, the supercritical project option is the most financially attractive baseline.
• The project's investment analysis used an unrealistic assumption that imported coal from Indonesia would cost 25% less than the open market spot price, which unduly favored the less efficient subcritical technology as the baseline.
• Applying the actual spot price of coal—which requires a 33% increase over the project's assumed price—demonstrates that supercritical technology is the most financially attractive baseline scenario.
• If registered, Project 3020 would generate 2.65 million CERs annually, which would make it the third largest non-HFC23 project ever registered under the CDM.

APA

Carbon Market Watch (2010). Implications of ACM0013 on GHG Emission Reductions through grid connected high efficiency power generation. https://carbonmarketwatch.org/wp-content/uploads/2010/05/analysis-of-project-3020-under-revised-acm0013-ver-21.pdf

Chicago

Carbon Market Watch. Implications of ACM0013 on GHG Emission Reductions through grid connected high efficiency power generation. 2010. https://carbonmarketwatch.org/wp-content/uploads/2010/05/analysis-of-project-3020-under-revised-acm0013-ver-21.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Implications of ACM0013 on GHG Emission Reductions through grid connected high efficiency power generation |date=26 March 2010 |url=https://carbonmarketwatch.org/wp-content/uploads/2010/05/analysis-of-project-3020-under-revised-acm0013-ver-21.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2010implications, author = {{Carbon Market Watch}}, title = {{Implications of ACM0013 on GHG Emission Reductions through grid connected high efficiency power generation}}, publisher = {Carbon Market Watch}, year = {2010}, month = mar, url = {https://carbonmarketwatch.org/wp-content/uploads/2010/05/analysis-of-project-3020-under-revised-acm0013-ver-21.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }