Feedback on the concept methodology ‘Early phase-out of coal fired thermal power plants and their replacement with green-field renewable energy generation plants’

Carbon Market Watch argues that Gold Standard's proposed methodology for crediting the early retirement of coal plants lacks the necessary rigor to ensure additionality and environmental integrity. The organization expresses skepticism that carbon credit finance is a suitable tool for this purpose given the volatility of energy markets and the difficulty of accurately measuring the future viability of coal plants. Specific concerns include the risk of double claiming, vague definitions of 'baseline plants' that might include economically unviable facilities, and the failure to account for the lifecycle emissions of new renewable energy plants.

• The proposed methodology does not sufficiently address loopholes regarding additionality and baseline setting, meaning it cannot be confirmed to meet the environmental integrity standards required for carbon crediting.
• Carbon Market Watch is skeptical that carbon credits can effectively incentivize early coal plant retirement because the political, economic, and societal forces influencing plant viability are too uncertain to be accurately measured.
• The current definition of a 'baseline plant'—requiring three years of uninterrupted commercial operation—is insufficient because it could include plants that are not economically viable, such as those operating at very low capacity (e.g., 10%).
• There is a risk of 'double claiming' if renewable energy technology receives additional financial support from other sources while also issuing carbon credits to the buyer.
• The methodology fails to account for the full lifecycle GHG footprint of the replacement renewable energy plants, specifically omitting emissions from construction and dismantling.

APA

Carbon Market Watch (n.d.). Feedback on the concept methodology ‘Early phase-out of coal fired thermal power plants and their replacement with green-field renewable energy generation plants’. https://carbonmarketwatch.org/wp-content/uploads/2023/04/Gold-Standard-consultation.pdf

Chicago

Carbon Market Watch. Feedback on the concept methodology ‘Early phase-out of coal fired thermal power plants and their replacement with green-field renewable energy generation plants’. n.d. https://carbonmarketwatch.org/wp-content/uploads/2023/04/Gold-Standard-consultation.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Feedback on the concept methodology ‘Early phase-out of coal fired thermal power plants and their replacement with green-field renewable energy generation plants’ |url=https://carbonmarketwatch.org/wp-content/uploads/2023/04/Gold-Standard-consultation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatchndfeedback, author = {{Carbon Market Watch}}, title = {{Feedback on the concept methodology ‘Early phase-out of coal fired thermal power plants and their replacement with green-field renewable energy generation plants’}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2023/04/Gold-Standard-consultation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }