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

This policy note by the Stockholm Environment Institute evaluates whether revisions to the ACM0013 methodology can resolve systematic flaws in awarding Certified Emission Reductions (CERs) to coal power projects under the Clean Development Mechanism (CDM). The authors argue that while some technical fixes are possible, fundamental challenges regarding data noise, additionality, and long-term climate goals make it unlikely that revised methodologies can ensure coal power CERs are real, measurable, and additional.

• Both the Stockholm Environment Institute and the CDM Methodologies Panel concluded that more than 50% of CERs issued to coal plants likely stem from systematic overestimation of emission reductions.
• The ACM0013 methodology suffers from a low signal-to-noise ratio, where non-project factors like coal quality, ambient conditions, and pollution controls can impact plant efficiency more than the boiler technology improvements being credited.
• Additionality assessments for coal projects are often tautological because nearly all supercritical projects in India and ultra-supercritical projects in China apply for CDM approval, meaning the common practice test fails as a credibility check.
• Investment analyses used to prove additionality are frequently unconvincing due to small differences in the cost of electricity between proposed projects and less efficient alternatives, and they often fail robust sensitivity analysis.
• The current pipeline of 45 coal power projects under ACM0013 provides only marginal efficiency gains while locking in over 400 million tonnes of annual CO2 emissions, potentially undermining the 2°C climate stabilization goal.
• Baseline calculations in India and China are often biased; for example, in India, project documents claim average emission improvements of 11%, whereas available market technologies suggest improvements of only 2-4% when moving from subcritical to supercritical technology.
• 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} }