Can Concerns with CDM Coal Power Projects be Addressed through Revisions to the ACM0013 Methodology?

The policy note argues that revisions to the ACM0013 methodology can only partially address the issues surrounding CDM coal power projects. It identifies three fundamental challenges: a low signal-to-noise ratio in efficiency data, the ineffectiveness of additionality assessments for multi-billion-dollar projects, and the contradiction of using climate finance to lock in long-lived, emissions-intensive infrastructure. The authors conclude that these combined factors likely defy easy resolution through methodology revisions alone.

• Both the Stockholm Environment Institute and the CDM Methodologies Panel concluded that more than 50% of the CERs issued to coal plants likely result from systematic overestimation.
• The 'signal-to-noise ratio' in ACM0013 is too low because non-project factors—such as coal quality, ambient conditions, and pollution controls—can impact plant efficiency more than the boiler technology improvements the methodology intends to credit.
• Additionality assessments for coal projects are often tautological and unconvincing because nearly all supercritical projects in India and ultra-supercritical projects in China apply for CDM approval, and the financial value of CERs is negligible compared to the scale of total investment and coal price volatility.
• The current pipeline of 45 coal power projects in the CDM risks locking in over 400 million tCO2 in annual emissions for several decades, which may undermine the global objective of limiting temperature increase to 2°C.
• Baseline calculations in India are often biased; while market data suggests efficiency improvements of 2-4% when moving from subcritical to supercritical technology, project design documents (PDDs) claim an average of 11%.
• The ACM0013 methodology may create perverse incentives by penalizing projects that install sulfur and particulate emission controls, as these controls can reduce net unit efficiency.

APA

Lazarus, M., & Chandler, C. (2011). Can Concerns with CDM Coal Power Projects be Addressed through Revisions to the ACM0013 Methodology? Stockholm Environment Institute. https://www.sei.org/wp-content/uploads/2023/11/sei-policynote-dec2011-cdm-coal-power.pdf

Chicago

Lazarus, Michael, and Chelsea Chandler. Can Concerns with CDM Coal Power Projects be Addressed through Revisions to the ACM0013 Methodology? Stockholm Environment Institute, 2011. https://www.sei.org/wp-content/uploads/2023/11/sei-policynote-dec2011-cdm-coal-power.pdf.

Wikipedia

{{cite report |last1=Lazarus |first1=Michael |last2=Chandler |first2=Chelsea |title=Can Concerns with CDM Coal Power Projects be Addressed through Revisions to the ACM0013 Methodology? |publisher=Stockholm Environment Institute |date=December 2011 |url=https://www.sei.org/wp-content/uploads/2023/11/sei-policynote-dec2011-cdm-coal-power.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{lazarus2011can, author = {Lazarus, Michael and Chandler, Chelsea}, title = {{Can Concerns with CDM Coal Power Projects be Addressed through Revisions to the ACM0013 Methodology?}}, institution = {Stockholm Environment Institute}, year = {2011}, month = dec, url = {https://www.sei.org/wp-content/uploads/2023/11/sei-policynote-dec2011-cdm-coal-power.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }