01
How the mechanism works 7
A SPARC stream is a slice of an existing coal PPA that a third party agrees to fulfill. More formally, it is a defined delivery band inside an existing coal PPA, carrying the right to supply power, to receive the associated payment, and use the embedded emission right, together with the corresponding delivery obligations.
The underlying PPA stays legally intact. No full buyout. No immediate plant closure.
SPARC changes who delivers energy under a fossil-fuel power contract. The contractual obligation remains in place, but production shifts: a renewable or lower-emission generator fulfills the SPARC stream instead of the fossil-fuel plant.
Coal load factors decline. Contracts stay intact.
A SPARC is created at delivery. When one eligible MWh is produced under a registered SPARC stream and evidenced through the required metering and attribute systems, a SPARC record is created.
There is no pre-issuance. SPARCs are not free-floating certificates.
Progressively. A SPARC stream covers a defined band of the PPA, which can be a small slice of total contracted delivery. Multiple SPARC streams can be registered and fulfilled over time, allowing a plant's dispatch load to decline incrementally while capacity remains available for grid security.
No. That is not the base case. SPARC does not require a coal plant to ramp up and down around intermittent renewable output. The cleaner starting point is a firm or near-firm delivery band inside the coal PPA that another delivery party agrees to fulfill.
Flexible SPARC streams may make sense in some cases, especially where the plant, delivery party, and system operator can handle shaped delivery. But SPARC's core coal case is contracted output substitution, not turning coal plants into renewable-balancing assets.
No. A coal plant can reduce output through SPARC stream fulfillment while remaining available or partially available. The output reduced under a fulfilled SPARC stream may not be redirected or sold elsewhere by the coal plant; that production band belongs to the stream and is what the substitute generator delivers.
Retirement may follow as a later economic outcome, but it is not a required step in the mechanism. As more SPARC streams are fulfilled, the remaining coal-backed obligation becomes smaller and more concrete, which can make later retirement, full substitution, or PPA renewal on cleaner terms easier to negotiate.
A virtual PPA creates a new commercial relationship between a renewable generator and a buyer, but it does not address the coal plant's existing contractual obligations. The coal plant's PPA can continue to support generation even if parallel clean energy has been procured elsewhere.
A SPARC stream is intended to work with the existing coal PPA. The delivery obligation shifts to a lower-emission generator, so the coal plant's contracted generation is displaced, not merely offset by a separate clean energy contract.
02
The deal structure 6
The two primary counterparties are the coal plant operator, which holds the PPA and originates the SPARC stream, and the delivery party, typically a renewable generator or developer that takes on the physical delivery obligation under the stream.
The grid counterparty remains a party to the original PPA.
The coal operator avoids fuel cost and sheds delivery risk. The delivery party gains access to guaranteed offtake inside an existing PPA contract and takes on performance obligations.
A portion of the PPA payment transfers to the delivery party, and ARC value may be allocated according to the SPARC stream agreement. The ARC price in SPARC's economic model is a derived output: what must be true for the deal to clear, not a fixed assumption fed into it.
Because SPARC can preserve the value of the PPA while reducing the operator's exposure. The coal operator keeps the PPA interface and retains value for fixed-cost recovery, debt service, margin, and residual obligations. For the substituted MWh, it can avoid fuel cost, variable operating cost, and selected delivery risk because another delivery party fulfills the SPARC stream.
In simple terms: the coal operator keeps much of the contract economics while reducing operating exposure. Over time, it also gets a way to make the contract cleaner from inside the existing PPA, rather than reaching expiry with a pure coal contract unchanged.
Under the preferred low-friction model, no. The PPA counterparty relationship does not change. The coal operator remains the grid-facing contractual party.
The SPARC stream agreement is designed to sit beneath the existing PPA and avoid full PPA novation where the jurisdiction permits that approach.
The delivery party takes on physical delivery obligations for the contracted band, replacement-power obligations if delivery fails, and defined performance standards set out in the SPARC stream agreement. These may reference the performance standards of the underlying PPA.
The SPARC stream agreement defines who bears replacement-power risk. In the base case, the delivery party bears that risk through financial penalties, replacement-energy obligations, or other agreed remedies.
The coal operator retains fallback rights consistent with its PPA obligations to the grid counterparty, so the grid counterparty’s position is intended to remain protected.
03
ARCs and carbon claims 6
An ARC is the unused emission right from a SPARC. It is issued when the verified emissions of the delivered MWh are lower than the embedded emission right carried by that SPARC.
ARCs are receipts, not advance claims.
Most voluntary carbon credits estimate reductions against a modeled counterfactual: what emissions would have occurred if the credited activity had not happened. That is especially difficult for coal retirement credits, because once the plant is closed, its future generation must be estimated rather than observed.
An ARC works from a different starting point. SPARC keeps the underlying contract active. When a SPARC stream is fulfilled, a coal-backed contractual MWh is actually called, delivered, and evidenced. If that MWh is delivered by a lower-emission generator, the ARC records the emission right that existed under the coal-backed contract but was not used.
The claim follows a live delivery event. It does not rely on a modeled future operating path.
A coal-retirement transition credit starts with the closure of the plant. The credit claim then depends on estimating how much that plant would have generated if it had stayed open.
ARC starts from a different event. The coal contract remains active. A SPARC stream is called for delivery, and the MWh is fulfilled by a lower-emission generator. The ARC records the unused emission right attached to that specific delivered MWh.
Transition credits model avoided future generation after closure. ARC records the lower-emission fulfillment of a live coal-backed contractual MWh.
Every SPARC stream carries the coal-backed emission right associated with the contracted MWh. That right is set through the applicable coal-plant emission factor, approved benchmark, ETS allocation, or other host-country-recognized method.
When the stream is fulfilled, the relevant question is factual: who delivered the called MWh, and with what verified emissions? If the delivery party fulfills that MWh with lower verified emissions than the embedded emission right, the difference is the unused emission right that becomes an ARC.
They are distinct records linked to the same delivery event. A SPARC records that a delivered MWh fulfilled a fossil-fuel contract under a SPARC stream. A Renewable Energy Certificate (REC) or equivalent energy-attribute certificate evidences that the MWh was generated from a qualifying renewable source. An ARC records the unused emission right created by that substitution.
They are not interchangeable and should not be collapsed into one claim.
ARC ownership is defined in the SPARC stream agreement. Either the coal operator, the delivery party, or both may receive a share of ARC value depending on how the deal is structured.
ARCs may be transferred, cancelled, retained, or used under domestic compliance pathways where the relevant framework permits it.
04
Regulatory and policy 5
SPARC is designed to operate within existing contractual and regulatory frameworks as far as possible. The preferred early pathway uses bilateral stream agreements structured beneath existing PPAs, rather than starting with full PPA novation or new legislation.
The required level of regulatory recognition depends on the jurisdiction, the transaction structure, and how dispatch, metering, and settlement are treated.
Regulators and system operators maintain dispatch and metering authority throughout. SPARC does not bypass their oversight.
Where a grid operator controls dispatch scheduling, the SPARC stream agreement must account for how the delivery party delivers or schedules eligible MWh under the recognized stream. Regulatory recognition of the stream may be required.
I-TRACK alignment is the intended product-code and tracking-system pathway for SPARC stream registration and ARC issuance. Accreditation has not yet been obtained.
The mechanism design may need to accommodate alternative registry arrangements depending on regulatory preference and market structure in each jurisdiction.
SPARC is being designed as a repeatable product-code mechanism, not a bespoke bilateral workaround. The core idea is to standardize the treatment of the delivery band, evidence chain, and unused emission right so transactions can be repeated across markets once the relevant authorities recognize the structure.
I-TRACK is relevant because energy-attribute tracking already operates at large scale. SPARC is more complex than a standard REC because it links lower-emission delivery to a coal-backed contractual band, but the registry logic is similar: define the evidence rules, then repeat the transaction.
SPARC is a proposed market mechanism. The design has not received regulatory approval in any jurisdiction.
All mechanism parameters, regulatory pathways, and commercial structures described in SPARC materials are indicative and subject to revision as we engage with operators, regulators, and market participants across the region.
05
Article 6 and international use 3
Not automatically. The answer depends on how the ARC is characterized and what claim the buyer makes. An ARC sold as an embedded energy attribute sits in a different legal category than a transferred mitigation outcome, and that distinction matters for how Article 6 authorization requirements apply.
SPARC is being designed with international tradeability as a core objective. The mechanism preserves domestic use, cancellation, and international pathways. The applicable treatment for any given transaction will depend on the host country's framework and how the parties structure the claim, and those details should be confirmed before a transaction is finalized.
SPARC streams and ARCs could provide an evidence layer for power-sector decarbonization within a domestic ETS. SPARC records eligible delivery under a registered stream; ARCs record the unused embedded emission right where verified emissions are lower than that right.
The ETS remains responsible for allowance rules, compliance obligations, and legal treatment of unused emission rights. SPARC provides delivery and registry evidence. It is a potential integration route, not a current approval.
CORSIA is not a current SPARC claim. ARCs could become relevant to aviation-sector carbon-market demand only if the methodology, registry, authorization, and host-country treatment meet the applicable eligibility rules.
CORSIA eligibility has not been confirmed. Any CORSIA pathway would require formal methodological and registry review.
06
Who can participate 4
SPARC is designed for coal plants operating under long-term power purchase agreements, typically with state-owned utilities or grid operators. The mechanism is most directly applicable where the PPA defines contracted delivery obligations that can be structured as transferable bands.
Plants in the Philippines and Thailand operating under IPP and EGAT PPA structures are reference cases for the initial design.
Yes. A developer can build a renewable project specifically to fulfill a SPARC stream. The stream can provide a contracted revenue anchor, which may support project finance where the delivery, permitting, interconnection, and credit risks are acceptable.
A developer without existing assets can structure a new project around one or more streams, provided delivery is fulfilled with eligible metered generation and the required attribute evidence.
Yes. Philanthropic capital can support early transactions by buying ARCs, underwriting early price discovery, or helping close the gap before ARC prices are established.
An ARC offtake commitment may help a renewable developer finance the generation asset that fulfills the SPARC stream, but it is not the mechanism’s economic foundation.
The funder pays for a delivered outcome, not a promise.
SPARC is being developed in Southeast Asia because that is where the need is most acute, but the mechanism is designed to work wherever coal plants operate under long-term offtake contracts. The underlying logic does not depend on any single regulatory framework.
Applying SPARC in a new market requires review of local PPA structures, dispatch rules, metering systems, and registry frameworks, but no fundamental redesign.