Request for Review of the Additionality of CDM Project 4533: Greenhouse Gas Emission Reductions Through Super Critical Technology – Coastal Andhra Power Ltd., India

A formal request by Sierra Club and CDM Watch to the CDM Executive Board to review the additionality of Project 4533 in India. The authors argue that the project does not meet CDM rules because the Government of India mandated supercritical technology, financing was already secured, and the project sponsor's own shareholder communications describe CDM credits as a 'new revenue stream' rather than a necessity for implementation. They further contend that the project's baseline assumptions regarding coal prices are unrealistically low and that alternative energy efficiency scenarios were ignored.

• The project is not additional because the Government of India's Request for Proposal (RfP) mandated that the units be based on supercritical technology, meaning the project is in compliance with mandatory regulations.
• The project does not depend on CDM support for implementation, as Coastal Andhra had already secured necessary financing and commenced construction, including purchasing land and Indonesian coal mines, prior to validation.
• Communications from the project sponsor, Reliance Power, to its shareholders contradict claims of additionality by stating the project will employ supercritical technology and viewing CDM credits as a profit center rather than a requirement.
• The project failed to evaluate alternative tariff structures that could have provided a sufficient rate of return without CDM support, a deficiency that led to the rejection of a similar Indian project (Project 3020).
• The sensitivity analysis used an implausibly low baseline coal price of US$23/ton and an unrealistically narrow price variation of +/-10%, despite actual contracts for Indonesian coal being signed at $28.28/ton.
• The project proponent failed to consider alternative baseline scenarios such as demand side management, improved end-use efficiency, and the reduction of transmission and distribution losses, which currently range between 35-40 percent in India.
• Subcritical coal technology is an inappropriate baseline for India because supercritical technology is already the standard for new large-scale plants, with 37 units under construction as of 2010 and 50 plants in implementation or planning.
• If registered, the project could result in the issuance of 12,346,977 CERs that do not represent additional reductions, potentially providing a windfall of approximately € 148 million.

APA

Carbon Market Watch (2011). Request for Review of the Additionality of CDM Project 4533: Greenhouse Gas Emission Reductions Through Super Critical Technology – Coastal Andhra Power Ltd., India. https://carbonmarketwatch.org/wp-content/uploads/2011/07/Unsolicited-letter_Sierra-Club-CDMWatch-Letter-Coastal-Andhra1.pdf

Chicago

Carbon Market Watch. Request for Review of the Additionality of CDM Project 4533: Greenhouse Gas Emission Reductions Through Super Critical Technology – Coastal Andhra Power Ltd., India. 2011. https://carbonmarketwatch.org/wp-content/uploads/2011/07/Unsolicited-letter_Sierra-Club-CDMWatch-Letter-Coastal-Andhra1.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Request for Review of the Additionality of CDM Project 4533: Greenhouse Gas Emission Reductions Through Super Critical Technology – Coastal Andhra Power Ltd., India |date=24 June 2011 |url=https://carbonmarketwatch.org/wp-content/uploads/2011/07/Unsolicited-letter_Sierra-Club-CDMWatch-Letter-Coastal-Andhra1.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatch2011request, author = {{Carbon Market Watch}}, title = {{Request for Review of the Additionality of CDM Project 4533: Greenhouse Gas Emission Reductions Through Super Critical Technology – Coastal Andhra Power Ltd., India}}, publisher = {Carbon Market Watch}, year = {2011}, month = jun, url = {https://carbonmarketwatch.org/wp-content/uploads/2011/07/Unsolicited-letter_Sierra-Club-CDMWatch-Letter-Coastal-Andhra1.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }