Review of the Additionality of the CDM Project 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology - Jharkhand Integrated Power, Ltd., India

Sierra Club CDM Watch submitted a letter to the CDM Executive Board arguing that Project 4629 in India is non-additional. The authors contend that the project would proceed regardless of CDM support because the Government of India mandates supercritical technology and the owner, Reliance Power, has already committed to such technology through a US$10 billion order. They further argue that the project's baseline scenario is flawed, fails to consider energy efficiency alternatives, and uses an unrealistically narrow coal price sensitivity analysis. If registered, the project could receive over 21 million CERs, potentially providing a windfall of approximately €257 million.

• The project is non-additional because the Government of India's Request for Proposal (RfP) mandates the use of supercritical technology, meaning the project would be implemented regardless of CDM credits.
• Reliance Power, the project owner, has demonstrated a corporate commitment to supercritical technology independent of CDM support, including a US$10 billion order for 42 units of 660MW supercritical BTG packages.
• Reliance Power's internal communications to shareholders contradict its claims to the CDM Executive Board, describing CERs as a "new revenue stream" rather than a necessary condition for the project's viability.
• The project sponsor failed to evaluate alternative tariff structures that could have provided an adequate rate of return without CDM support, a failure that led the Executive Board to reject a similar Indian supercritical plant (Project 3020).
• The baseline scenario analysis is deficient because it ignores energy efficiency alternatives, such as demand side management and the reduction of transmission and distribution losses, which could eliminate the need for up to 30 GW of additional capacity.
• The use of subcritical coal technology as a baseline is inappropriate because supercritical technology is already the preferred choice for large-scale plants in India, with 37 units between 660 MW and 800 MW under construction as of 2010.
• The project's sensitivity analysis uses an unrealistically narrow coal price fluctuation of +/-10% and a starting price of $15/ton, which is 38% lower than the 2008 average Indian coal price.
• There is insufficient evidence that supercritical technology will lead to additional CO2 reductions, as site-specific factors in India (such as poor coal quality) can result in efficiencies lower than those of subcritical plants.

APA

Carbon Market Watch (2011). Review of the Additionality of the CDM Project 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology - Jharkhand Integrated Power, Ltd., India. https://carbonmarketwatch.org/wp-content/uploads/2011/07/Sierra-Club-CDM-Watch_Unsollicited-Letter_Project-4629_Jharkhand_05072011.pdf

Chicago

Carbon Market Watch. Review of the Additionality of the CDM Project 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology - Jharkhand Integrated Power, Ltd., India. 2011. https://carbonmarketwatch.org/wp-content/uploads/2011/07/Sierra-Club-CDM-Watch_Unsollicited-Letter_Project-4629_Jharkhand_05072011.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Review of the Additionality of the CDM Project 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology - Jharkhand Integrated Power, Ltd., India |date=5 July 2011 |url=https://carbonmarketwatch.org/wp-content/uploads/2011/07/Sierra-Club-CDM-Watch_Unsollicited-Letter_Project-4629_Jharkhand_05072011.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 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology - Jharkhand Integrated Power, Ltd., India}}, publisher = {Carbon Market Watch}, year = {2011}, month = jul, url = {https://carbonmarketwatch.org/wp-content/uploads/2011/07/Sierra-Club-CDM-Watch_Unsollicited-Letter_Project-4629_Jharkhand_05072011.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }