M-ICR010
Public consultation on the first version from 18. December 2025 - 29. January 2026
Coal Abatement for the Energy Transition
Methodology developer
Sectoral scope
Mining/Minerals
ID:
M-ICR010
Summary:
This methodology is for the development of projects that permanently avoid the mining and combustion of commercially viable coal assets. This methodology is globally applicable. A project-specific Declaration of a Reserve will detail the volumes of coal (and optionally also methane) that it would be economically viable and technically feasible to extract under current conditions. The Declaration of a Reserve shall be developed in conformance with an accepted standard or code, and shall have been completed no more than 24 months prior to the Project Start Date. The Declaration of a Reserve will typically include:
Geological Assessment: Analysis of the coal deposit's structure, thickness, depth, and quality (e.g., calorific value, sulfur content).
Economic Feasibility: Determination of whether extracting the coal is profitable given market conditions, production costs, and potential revenues.
Technical Viability: Assessment of whether existing technology and mining methods can effectively and safely extract the coal.
Legal and Regulatory Compliance: Verification that mining the deposit complies with local, national, and international laws and regulations.
Environmental and Social Considerations: Evaluation of the potential impacts of mining on the environment and nearby communities, and plans for mitigation.
Under this methodology multiple non-contiguous mineral rights/assets can be brought together, under one or more Declarations of a Reserve, and developed as a single project. The project proponent will demonstrate a legal right to a mining license to implement mining activities. The project proponent will then implement legal mechanisms to permanently prohibit the coal from being extracted. Project proponents will be required to demonstrate project revenues are not used to develop and extract coal assets elsewhere. Project proponents will also be required to demonstrate that permanent legal barriers have been put in place that prohibit any material declines in aboveground woody biomass and Soil Organic Carbon. A monitoring plan will be put in place to ensure the coal is permanently sequestered, and other mandatory project aspects are implemented. Quantification of emission reductions will be simple, conservative, and robust, coupling published emission factors, with expert-derived studies. A robust, conservative, and significant leakage deduction will be applied to all projects. Significant Sustainable Development Goal (SDG) co-benefits will be realized and monitored by all projects developed under this methodology. Projects developed under this methodology will send a profound signal to the market, that it is cost-effective to permanently retire commercially viable coal assets, thus driving emission reductions at significant scale.
Documentation and public consultation
Public consultation 18. December 2025 - 29. January 2026
Public consultation form
Public comments
Comment 1: Anonym comment
I appreciate the ambition of this methodology and the recognition that avoiding future fossil fuel extraction is necessary for alignment with climate goals. Avoided extraction methodologies, however, face uniquely high integrity risks relative to other abatement categories, particularly when credits are issued against counterfactual future production rather than historical emissions. As such, the burden of proof for additionality, baseline robustness, leakage control, and governance must be especially high. My comments below are intended to strengthen the credibility and market confidence of this methodology by identifying areas where current provisions appear insufficiently robust given the scale of emissions claimed. 1. Additionality and Baseline Credibility 1.1 Reliance on pre-mining reserve declarations as a proxy for certainty The methodology relies heavily on a project-specific Declaration of a Reserve to establish both the quantity and timing of baseline coal extraction (Sections 6 and 7). While reserve reporting standards such as JORC, NI 43-101, and SEC S-K 1300 are appropriate for capital markets disclosure, they were not designed to predict with certainty that extraction will occur on a specific timeline, or at all. Critically, the methodology does not require evidence that: Historically, coal projects with similar reserve declarations actually proceeded to development, The production volumes and timelines in those declarations were realized, Or that deviations from planned extraction schedules were uncommon. Without such empirical validation, the baseline risks overstating emissions by assuming deterministic extraction of speculative future production. This risk is fundamentally different from methodologies that credit early closure of operating coal mines, where historical production data can be used to anchor counterfactual projections. In contrast, this methodology credits projects before any emissions source exists, which substantially increases uncertainty and the risk of non-additional issuance. Suggested clarification or safeguard: Require a jurisdiction-specific or basin-specific analysis demonstrating how often reserve declarations result in developed mines, and how often projected volumes and timelines are met. Apply conservative discounting factors to reserve-based baselines unless such empirical evidence is provided. Consider limiting eligibility to assets that have reached defined late-stage permitting or financing milestones. 2. Upfront Credit Issuance and Incentive Alignment The methodology explicitly allows for full issuance of credits at first issuance, contingent on modeling leakage over the full mining lifetime (Section 8.1.3(v)). Given the high uncertainty in: Whether extraction would have occurred, When it would have occurred, How much coal would ultimately have been produced, And how markets would respond over decades, upfront issuance appears fundamentally misaligned with risk management best practices. Once credits are fully issued: The incentive for continued monitoring diminishes, Activity-shifting attestations lose practical enforceability, Reversal risk becomes asymmetric, with buyers exposed long after credits are sold. This is particularly concerning given that the methodology acknowledges abandonment risk and political risk as material (Appendix I). Suggested clarification or safeguard: Require annual or periodic issuance tied to the counterfactual production schedule. Prohibit upfront issuance until a meaningful portion of the baseline period has elapsed. If upfront issuance is retained, require substantially higher buffer contributions or escrow mechanisms. 3. Emissions Quantification and Independence While the methodology requires independent experts to prepare reserve declarations, the project proponent retains significant control over baseline inputs and quantification assumptions, particularly regarding: Annual extraction profiles, Coal quality assumptions, Methane inclusion decisions, Leakage model selection. In methodologies where avoided emissions dominate total credit volume, developer-led quantification creates structural incentive risk, even when third-party validation is present. Notably, the VVB is explicitly not required to assess the reasonableness of the Declaration of a Reserve itself (Section 6), limiting the effectiveness of independent oversight. Suggested clarification or safeguard: Require independent third-party development (not just validation) of baseline production schedules and emissions calculations. Mandate disclosure of all reserve modeling assumptions and sensitivity analyses in public documentation. Require the VVB to assess not only consistency, but plausibility of reserve-based baselines. 4. Leakage: Activity Shifting and Market Leakage 4.1 Activity shifting attestation lacks enforceable recourse The methodology relies on an attestation that project revenues will not be used to develop coal assets elsewhere (Applicability Condition 9), while explicitly noting that the attestation is not necessarily legally enforceable. Given that activity shifting is a primary risk in avoided extraction methodologies, this approach appears insufficient. Key questions remain unanswered: What constitutes evidence of violation? Who monitors capital allocation beyond the project boundary? What remedies apply if the attestation is breached after credits are issued? Suggested clarification or safeguard: Require legally binding covenants, not attestations. Define clear monitoring, disclosure, and enforcement mechanisms. Specify remedies that go beyond project ineligibility after the fact. 4.2 Market leakage left undefined at methodology approval Market leakage is acknowledged as the single largest emissions risk, yet the methodology allows projects to register before leakage factors are finalized, stating that they will be “determined at registration” (Section 8.1.3). This raises several concerns: Methodology approval occurs without clarity on acceptable leakage ranges. There is no predefined governance standard for who validates leakage assumptions. Different projects could apply materially different leakage factors under the same methodology. It is unclear whether any other ICR methodologies permit registration with such a critical parameter unresolved. Suggested clarification or safeguard: Define minimum conservative leakage floors at the methodology level. Require independent, standardized leakage models approved by ICR. Subject leakage assumptions to heightened public and technical review prior to registration. 5. Additional Integrity Risks to Consider Based on experience with fossil fuel abatement methodologies, additional risks warrant attention: 5.1 Over-crediting due to energy system dynamics Avoided coal supply does not necessarily translate into avoided coal combustion if: Demand remains inelastic, Alternative coal sources fill the gap, Or coal is stockpiled for later use. While leakage modeling attempts to address this, the uncertainty compounds over multi-decade horizons. 5.2 Permanence framed as legal rather than economic Legal barriers may prohibit mining, but economic and political pressures can erode permanence over time. Treating avoided extraction as equivalent to physical sequestration risks overstating durability. 5.3 Buyer perception and market confidence Even if technically compliant, credits perceived as speculative or overly modeled risk undermining confidence in fossil fuel abatement credits more broadly. Avoiding future coal extraction is a critical climate objective. However, methodologies that credit non-existent emissions sources must meet a higher evidentiary standard than those that mitigate or shut down operating assets. Strengthening requirements around additionality, issuance timing, independent quantification, and leakage governance would materially improve the credibility and durability of this methodology and help ensure that issued credits represent real, additional, and durable climate benefits. Thank you for the opportunity to comment.
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Comment 2: Perspectives
A baseline and monitoring methodology for leaving fossil fuels in the ground is an aberration. Leaving fossil fuels in the ground is structurally unfit for carbon credit generation, as it cannot satisfy key environmental integrity criteria. Additionality of leaving fossil fuels in the ground cannot convincingly be proven. There is no credible way of guaranteeing permanence, as the fossil fuel reservoir can be exploited any time. Please find a detailed critique of leaving fossil fuel in the ground approaches in my attached research article: Köhler, Michel; Michaelowa, Axel (2014): Limiting Climate Change by Fostering Net Avoided Emissions, in: Carbon and Climate Law Review, 1/2014, p. 55-64. ICR should therefore not register this methodology.
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Comment 3: Anonym comment
Supply-side coal reduction of economic reserves is a sound and timely method of reducing global demand of thermal coal. Reducing supplies raises costs; raising costs reduces demand; and creates demand for cleaner cost-effective energy sources. Congrats!
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Comment 4: Anonym comment
This methodology has been needed for a long time. These types of projects will be real change and large-scale financing opportunities to the VCM market.
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Comment 5: GB Energy Engineering & Consulting
(submitted in the attachment)
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