Coal Power in the CDM: Issues and Options

This research paper by the Stockholm Environment Institute examines the application of CDM Methodology ACM0013 for coal power projects, arguing that systemic flaws in the methodology and its application lead to significant over-crediting of Certified Emission Reductions (CERs) and a failure to ensure project additionality.

• As of October 2011, the CDM coal project pipeline consisted of 45 projects located exclusively in India and China, with a total capacity of 79 GW (56 GW in India and 23 GW in China). If approved and performing as projected, these projects would generate 451 million CERs, with 90% of those coming from India.
• The authors argue that coal projects in the pipeline are likely non-additional, meaning they would have proceeded without CDM support. This is attributed to rising international coal prices and government policies in India and China that mandate or encourage the use of supercritical and ultra-supercritical technologies to increase efficiency.
• Systemic flaws in the ACM0013 methodology lead to substantial over-estimation of emission reductions. Specifically, developers use outdated historical data and identify subcritical technology as the baseline even though the industry has transitioned away from it. In India, projects claim efficiency improvements of at least 11% on average, while market specifications suggest improvements are actually between 2% and 4%.
• The authors estimate that the combined effect of these methodological flaws could result in over-crediting of approximately 250%. They calculate that the pipeline should yield 132 million CERs rather than the projected 451 million CERs.
• The ACM0013 methodology suffers from a low signal-to-noise ratio because it does not control for variables other than boiler technology—such as cooling technology, fuel quality (moisture, ash, and sulfur content), and pollution abatement equipment—which can affect unit efficiency by 7% or more.
• The authors conclude that supporting coal investments through the CDM may undermine global climate goals, as coal plants produce twice the emissions per kilowatt-hour of new natural gas plants. They suggest that sectoral crediting or trading at the electricity sector-wide level would be a better alternative to avoid over-crediting and non-additionality.

APA

Lazarus, M., & Chandler, C. (2011). Coal Power in the CDM: Issues and Options. Stockholm Environment Institute. https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/SEI-WP-2011-02-Coal-in-CDM-ES.pdf

Chicago

Lazarus, Michael, and Chelsea Chandler. Coal Power in the CDM: Issues and Options. Stockholm Environment Institute, 2011. https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/SEI-WP-2011-02-Coal-in-CDM-ES.pdf.

Wikipedia

{{cite report |last1=Lazarus |first1=Michael |last2=Chandler |first2=Chelsea |title=Coal Power in the CDM: Issues and Options |publisher=Stockholm Environment Institute |date=November 2011 |url=https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/SEI-WP-2011-02-Coal-in-CDM-ES.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{lazarus2011coal, author = {Lazarus, Michael and Chandler, Chelsea}, title = {{Coal Power in the CDM: Issues and Options}}, institution = {Stockholm Environment Institute}, year = {2011}, month = nov, url = {https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/SEI-WP-2011-02-Coal-in-CDM-ES.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }