Review of the Additionality of the CDM Project 4785: Guangdong Pinghai Power Plant, China

The Sierra Club CDM Watch requests that the CDM Executive Board reject the registration of the Guangdong Pinghai Power Plant in China. The authors argue the project is non-additional because it was operational before validation, ultra-supercritical coal technology is already common practice in China, and the project's financial analysis is flawed, failing to consider alternative tariff structures or realistic coal price fluctuations.

• The project is considered non-additional because it was fully financed and operational before CDM validation or registration; Unit 1 began operations in October 2010 and Unit 2 in July 2011.
• Ultra-supercritical coal technology is already a common practice in China, with the International Energy Agency reporting 10 GW of such generation in operation as early as 2007 and expecting 80-90 GW by 2020.
• The project's investment analysis is flawed because the difference in levelized cost of energy (LCOE) between the ultra-supercritical project and the supercritical baseline is very small (0.00037 Euro/kWh), making additionality claims tenuous.
• The project sponsor failed to evaluate alternative tariff structures that could have allowed the project to meet its return on equity (ROE) benchmark without CDM revenue.
• The Validation Report's sensitivity analysis is inadequate as it only considers a +/- 10 percent coal price range, whereas actual price fluctuations in China have reached at least 60 percent.
• The Validation Report failed to assess realistic and credible baseline alternatives, such as natural gas, wind, solar, hydro, biomass, or energy efficiency and demand side management.

APA

Carbon Market Watch (2011). Review of the Additionality of the CDM Project 4785: Guangdong Pinghai Power Plant, China. http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch_Letter-opposing-registration-Project-4785-Guangdong-Pinghai.pdf

Chicago

Carbon Market Watch. Review of the Additionality of the CDM Project 4785: Guangdong Pinghai Power Plant, China. 2011. http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch_Letter-opposing-registration-Project-4785-Guangdong-Pinghai.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Review of the Additionality of the CDM Project 4785: Guangdong Pinghai Power Plant, China |date=30 September 2011 |url=http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch_Letter-opposing-registration-Project-4785-Guangdong-Pinghai.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2011review, author = {{Carbon Market Watch}}, title = {{Review of the Additionality of the CDM Project 4785: Guangdong Pinghai Power Plant, China}}, publisher = {Carbon Market Watch}, year = {2011}, month = sep, url = {http://carbonmarketwatch.org/wp-content/uploads/2011/09/Sierra-Club-CDM-Watch_Letter-opposing-registration-Project-4785-Guangdong-Pinghai.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }