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Coal Power in the CDM: Issues and Options
The report examines the CDM methodology ACM0013 used to award emission reduction credits to coal projects in India and China. It finds that the methodology is systematically flawed, leading to an estimated 250% over-crediting of Certified Emission Reductions (CERs). The authors argue that most projects are non-additional because the transition to supercritical and ultra-supercritical technology is already driven by rising coal prices and national policies. Furthermore, the report highlights a low signal-to-noise ratio where factors other than boiler technology significantly impact efficiency, making verifiable emission reductions difficult to estimate. The authors conclude that using climate finance to support coal investments may undermine global climate goals and suggest sectoral crediting as a more robust alternative.
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Document type: Research paper
Bioenergy Projects and Sustainable Development: Which Project Types Offer the Greatest Benefits?
The analysis finds that bioenergy projects relying on on-farm residues claim the highest number of sustainable development benefits, while those using industrial forestry residues claim the fewest. Most projects focus on economic and environmental benefits, with very few social benefits beyond stakeholder participation.
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Document type: Research paper
Private Finance Support Climate Change Adaptation in Developing Countries?
The research examines historical private capital flows—including foreign direct investment (FDI), portfolio equity, and bank lending—to assess their suitability for climate adaptation in developing countries. It finds that private finance is heavily concentrated in a few emerging economies and resource-extraction sectors, often bypassing the Least Developed Countries (LDCs) and critical adaptation sectors like water and small-scale agriculture. The author argues that the unpredictability and sectoral bias of private investment pose significant challenges for the delivery of the USD 100 billion annual climate finance pledge, suggesting that public finance must fill these gaps rather than simply attempting to leverage private flows that naturally avoid the most vulnerable areas.
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Document type: Research paper
Review of the Additionality of the CDM Project 4785: Guangdong Pinghai Power Plant, China
The Sierra Club CDM Watch requests that the CDM Executive Board reject the registration of the Guangdong Pinghai Power Plant in China. The authors argue the project is non-additional because it was operational before validation, ultra-supercritical coal technology is already common practice in China, and the project's financial analysis is flawed, failing to consider alternative tariff structures or realistic coal price fluctuations.
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Document type: Statement
Why coal projects in the CDM undermine climate goals
The document asserts that coal projects in the Clean Development Mechanism (CDM) are non-additional, conflict with sustainability goals by harming local ecosystems, and lock in long-term CO2 emissions. It further claims that flawed CDM rules lead to significant over-crediting of these projects, which are often used merely as an additional revenue stream for planned investments.
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Document type: Policy brief
Changements climatiques et réduction de la pauvreté
The document examines the intersection of climate change and poverty, highlighting how climate variability makes it harder for the poor to escape poverty. It advocates for a shift toward 'climate-resilient development' by integrating adaptation into national poverty reduction strategies, investing in evidence-based data, and ensuring inclusive processes that involve climate-vulnerable poor populations. The brief notes that while 'triple win' solutions (combining mitigation, adaptation, and poverty reduction) are desirable, they are difficult to implement and often fail to reach the poorest populations. It emphasizes that public investment is essential, as private sector investment alone cannot meet the needs of the Millennium Development Goals (MDGs) and adaptation requirements, particularly in Africa.
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Document type: Policy brief
Alterações climáticas e a redução da pobreza
The document highlights how climate variability makes it harder for poor populations to escape poverty and threatens the achievement of Millennium Development Goals (MDGs). It calls for a shift from treating adaptation and development as separate entities toward a unified approach of 'climate-resilient development'. Key recommendations include investing in evidence-based data on climate-poverty links, ensuring national ownership of strategies, and prioritizing mitigation only when it offers clear co-benefits for poverty reduction and adaptation.
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Document type: Policy brief
GAME-CHANGER OR COMPLEMENT? THE POTENTIAL OF PUBLIC FINANCE INSTRUMENTS FOR COVERING RISKS AND FACILITATING LOW-CARBON INVESTMENTS IN DEVELOPING COUNTRIES
The document investigates whether public finance-facilitating tools can act as a 'game-changer' for low-carbon investment in developing countries. It identifies that while these tools can address various risks and increase liquidity, they are not a substitute for ambitious climate policies and direct payment mechanisms. Key challenges include a lack of 'deal flow' in less advanced economies, the risk of crowding out private capital, and the inherent risk-aversion of public finance institutions that must maintain high credit ratings.
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Document type: Research paper
Message to Obama: Free America from the Tyranny of Oil
The Center for International Environmental Law (CIEL) advocates against the Keystone XL pipeline, citing the high greenhouse gas emissions of Alberta's tar sands and concerns over political influence in the State Department's permitting process. The statement also details CIEL's efforts to eliminate coal funding in international finance institutions, specifically criticizing World Bank loans for coal projects in South Africa and Kosovo, while referencing IPCC findings that renewables could meet nearly 80 percent of global energy supply by mid-century.
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Document type: Statement
Review of the Additionality of CDM Project 4807: Energy Efficient Power Generation by Nabha Power Limited, India
Sierra Club CDM Watch requests the CDM Executive Board to reject the registration of Project 4807, asserting that the use of supercritical technology was mandated by the Punjab State Electricity Board and is already the industry standard in India. The authors claim the project is not additional because financing was secured independently of CDM support and that the Validation Report used manipulated cost estimates and an inappropriate baseline to justify the project's economic viability.
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Document type: Statement
Cambio climático y reducción de la pobreza
The policy brief examines the intersection of climate change and poverty reduction, highlighting how climate instability undermines Millennium Development Goals (MDGs), particularly in Sub-Saharan Africa. It advocates for a shift from treating adaptation and development as separate entities toward a 'climate-resilient development' approach. The author emphasizes the need for evidence-based, country-led policies that prioritize the most vulnerable and suggests that mitigation efforts should only be pursued when they offer clear co-benefits for poverty reduction and adaptation.
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Document type: Policy brief
Climate change and poverty reduction
The document highlights how climate change undermines development goals and poverty eradication, specifically in Sub-Saharan Africa. It argues that the artificial distinction between adaptation and development must be removed in favor of climate resilience. The author calls for a stronger evidence base on climate-poverty links, the integration of adaptation into national poverty reduction strategies, and a cautious approach to mitigation that prioritizes developmental co-benefits over high opportunity costs.
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Document type: Policy brief
Trade Zones: Recommendations for South Africa
The document examines South Africa's industrial development zones (IDZs), established in 2000, and argues that current incentives are insufficient to attract necessary foreign investment. By comparing South African IDZs with special trade zones in the EU, US, Mercosur, India, and China, the author identifies gaps in regulatory, financial, and fiscal incentives. The paper recommends that the South African government introduce specific IDZ incentives, such as easing labour-market requirements and providing infrastructure and wage subsidies, while expanding the scope of these zones to include trade-related service industries.
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Document type: Research paper
Concerns over the failure to consider our request for review of the additionality of CDM Project 4533: Greenhouse Gas Emission Reductions Through Super Critical Technology – Coastal Andhra Power Ltd., India
Sierra Club and CDM Watch object to the CDM Secretariat's decision to disregard a June 2011 letter requesting a review of the additionality of CDM Project 4533 (Coastal Andhra Power Ltd., India). The authors argue that the Secretariat's failure to forward the letter to the CDM Executive Board before the July 3 deadline—based on a minor project number error—undermines the CDM's credibility and transparency. They highlight that the project is high-risk, seeking over 12 million CERs while generating 215 million tons of CO2 emissions, and call for clarified guidelines on stakeholder engagement and the forwarding of public concerns.
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Document type: Statement
Comments on the Second Project Design Document and Application for Validation after Rejection of Registration by CDM Executive Board GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India
CIEL opposes the validation of the Coastal Gujarat Power Ltd. project, citing a failure to properly record local stakeholder concerns in the Project Design Document (PDD) and alleging that the project's use of a once-through sea water cooling system violates Indian environmental law and harms marine ecology.
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Document type: Statement
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.
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Document type: Statement
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.
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Document type: Statement
Clarifying requirements that stipulate who is allowed to make submissions for revision and clarification requests of approved methodologies
Carbon Market Watch requests that the CDM Executive Board define who can submit methodology revisions and clarifications, arguing that allowing all stakeholders—not just project participants—is essential for the integrity of the Clean Development Mechanism.
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Document type: Statement
HOW TO ENABLE THE PRIVATE SECTOR TO MITIGATE?
The research paper examines indirect tools—capacity building and the creation of enabling environments—to remove non-financial barriers for low-carbon business activities in developing countries. It analyzes past experiences with the Clean Development Mechanism (CDM), identifies gaps in current international climate finance, and provides recommendations for the post-2012 climate regime, emphasizing the need for demand-driven, coordinated efforts and a stronger focus on the core regulatory business environment.
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Document type: Research paper
Carbon Fat Cats 2011
The report identifies the 'Carbon Fat Cats'—ten companies, primarily in the steel and cement sectors, that amassed a combined surplus of 240 million emissions allowances between 2008 and 2010, valued at approximately €4.1bn. This over-allocation is attributed to inflated growth projections and the economic recession, allowing these firms to profit through windfall sales or banking permits for future use. In contrast, the power sector faces a significant deficit, effectively subsidising industrial surpluses. The report also highlights the use of cheap international offsets, some from direct rivals in China and India, which undermines industry claims regarding competitiveness and carbon leakage. Sandbag recommends increasing the EU emissions reduction target to 30%, implementing an allowance 'set-aside' for Phase III, restricting the use of offsets from rival industries, and improving data transparency regarding company ownership and waste gas transfers.
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Document type: Report