Review of the Additionality of CDM Project 4807: Energy Efficient Power Generation by Nabha Power Limited, India

Sierra Club CDM Watch requests the CDM Executive Board to reject the registration of Project 4807, asserting that the use of supercritical technology was mandated by the Punjab State Electricity Board and is already the industry standard in India. The authors claim the project is not additional because financing was secured independently of CDM support and that the Validation Report used manipulated cost estimates and an inappropriate baseline to justify the project's economic viability.

• The project is not additional because the Punjab State Electricity Board (PSEB) mandated the use of supercritical technology as a condition for bid eligibility and in the Power Purchase Agreement.
• Nabha Power does not require CDM support to proceed as it has already secured all necessary financing and has already begun implementation, including ordering a 13 km rail link and contracting supercritical boilers.
• The Validation Report used inflated project costs (95,000 million INR) and underestimated subcritical alternative costs (40,223 million INR), potentially due to a non-arm's length contract between Nabha Power and its parent company, Larsen & Toubro Ltd.
• The project failed to evaluate realistic baseline alternatives, including energy efficiency programs, transmission and distribution loss reductions, and solar thermal power.
• Supercritical technology is the current standard for large-scale coal plants in India, making it a more appropriate baseline than subcritical technology.
• The Validation Report ignored E+ guidelines by failing to account for state-owned Coal India's subsidies, which give an unfair advantage to inefficient coal plants.
• The sensitivity analysis in the Validation Report used an unrealistically narrow fuel price variation of +/- 10%, ignoring severe coal shortages and rising prices in India.

APA

Carbon Market Watch (2011). Review of the Additionality of CDM Project 4807: Energy Efficient Power Generation by Nabha Power Limited, India. http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch-Letter-opposing-registration-Nabha-Power-Limited-FINAL.pdf

Chicago

Carbon Market Watch. Review of the Additionality of CDM Project 4807: Energy Efficient Power Generation by Nabha Power Limited, India. 2011. http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch-Letter-opposing-registration-Nabha-Power-Limited-FINAL.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Review of the Additionality of CDM Project 4807: Energy Efficient Power Generation by Nabha Power Limited, India |date=3 August 2011 |url=http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch-Letter-opposing-registration-Nabha-Power-Limited-FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2011review, author = {{Carbon Market Watch}}, title = {{Review of the Additionality of CDM Project 4807: Energy Efficient Power Generation by Nabha Power Limited, India}}, publisher = {Carbon Market Watch}, year = {2011}, month = aug, url = {http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch-Letter-opposing-registration-Nabha-Power-Limited-FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }