Which coal projects are suitable for CCER development?
Preface
Methane (CH4) is the second-largest greenhouse gas emitted by human activities after carbon dioxide (CO2). Over a 100-year time scale, methane's global warming potential (GWP) is 28 times that of CO2, as stated in the "Methodology for Greenhouse Gas Voluntary Emission Reduction Projects: Utilization of Low-Concentration Coal Mine Gas and Ventilation Air Methane" (hereinafter referred to as the "Methodology") issued by the Ministry of Ecology and Environment in 2025.
The release of the Methodology has spurred enthusiasm among coal mines and financial institutions for developing coal mine gas CCER (China Certified Emission Reduction) projects. However, confusion remains, as the Methodology does not explicitly specify which coal mines are suitable for CCER development. Based on the Methodology, combined with my understanding and project experience, I offer the following guidelines:
01
It should be an underground coal mine
· Excludes abandoned or closed underground mines.
· This is the first condition in the Methodology. Open-pit coal mines have extremely low gas content in coal seams and lack collection feasibility. While abandoned or closed underground mines may have residual gas, the quantity is unstable and diminishes over time. Thus, only actively operating underground coal mines qualify.
02
Mine’s recoverable lifespan must exceed 12 years
The Methodology states:
"The project crediting period is the maximum duration for registering emission reductions, starting from the project owner’s application, and shall not exceed 10 years. The crediting period must fall within the project’s total lifespan."
In simple terms, CCER revenue is capped at 10 years, so preparation time (e.g., project construction, CCER issuance) must be factored in.
03
Annual production capacity of 900,000 tonnes or more
Public data and field surveys show that most mines with ≥ 900,000 tonne annual output have gas extraction rates ≥10 m³/min. Using flameless oxidation for destruction (whether for heat or power generation), CCER incentives can achieve an internal rate of return (IRR) exceeding 8%.
04
Must have high- and low-negative-pressure gas extraction systems
The Methodology specifies that CCER projects utilize coal mine gas with concentrations below 8%.
· High-negative-pressure systems typically extract gas >8%.
· Low-negative-pressure systems extract gas <8%.
· Without a high-negative-pressure system, the low-negative-pressure system’s extracted gas may have insufficient concentration and flow rates.
05
Mines with existing internal combustion power plants are generally viable
· Gas-fired power generation is more efficient than flameless oxidation, leading to higher IRR. However, such projects fail the "additionality" requirement under the Methodology and thus cannot qualify for CCER.
· Mines with existing internal combustion generators usually have sufficient gas concentration and volume for flameless oxidation systems.
06
On-site heat demand or convenient grid access for power generation
The Methodology mandates that heat from gas destruction must be utilized (e.g., power generation, heating, or combined heat and power).
· Heating yields the highest annual emission reductions.
· If no heat demand exists, easy grid access for power generation is critical. Some regions have low electricity prices or high grid-connection barriers, making CCER development less viable.
Conclusion
Coal mine gas is both an energy source and a resource.
Its rational use delivers social and economic benefits.
Under China’s dual-carbon goals, gas utilization is significant—
but not all mines are suitable for CCER projects.