Dear Priyantha Wijayatunga, Senior Director, Energy Sector Office, Asian Development Bank
Big Shift Global is an international coalition of over 50 civil society organizations committed to ending public financial support for fossil fuels and promoting a just and equitable transition to renewable energy. The coalition closely monitors public finance institutions and advocates for alignment with climate goals and community needs, particularly in the Global South.
On behalf of the Big Shift Global coalition and affected communities across the Global South and beyond, we write to express our serious concerns regarding the proposed amendments to ADB’s 2021 Energy Policy, particularly those related to gas expansion, carbon capture and storage (CCUS), and the inclusion of so-called "clean" fuels such as green hydrogen and ammonia. We are also deeply concerned about the non-participatory nature of the consultation process and the limited timeframe provided, which does not allow for meaningful engagement.
We recognize that ADB’s 2021 Energy Policy made important strides in aligning energy investments with climate goals, but the recent review and consultations, including on 22 July 2025, have revealed a troubling shift. The direction and language emerging from ADB now openly supports midstream and downstream gas infrastructure, presenting gas as Paris-aligned and central to energy transition. This not only undermines the spirit of the Paris Agreement and the NDCs of borrower countries, but actively risks locking countries into high-carbon, high-debt pathways.
1. Gas is a False Solution – Dirty, Costly, and Dangerous
The evidence is unequivocal: gas is not a clean fuel. It is a potent fossil fuel whose combustion emits carbon dioxide, and its full life-cycle impact is even more dangerous due to methane emissions released across the value chain—from extraction to processing and transmission. Methane is over 80 times more potent than CO₂ over a 20-year period, making it a climate super-pollutant. These emissions cannot be fully mitigated by reduction or capture technologies, and continued investment risks locking in long-term emissions and infrastructure incompatible with a 1.5°C pathway.
Far from being economically viable, gas infrastructure traps countries—especially in the Global South—into long-term debts. Circular debt linked to gas subsidies and contracts has already overwhelmed energy sectors in countries like Pakistan and Bangladesh. This debt burden restricts fiscal space for investment in truly clean energy and exacerbates inequality. As highlighted in the recent UN report supercharging the new energy era, investments in renewables offer a far more affordable path for countries and citizens to achieve universal energy access while boosting energy security and sovereignty.
Communities suffer from the environmental degradation caused by gas: water and air pollution, threats to biodiversity and marine ecosystems, and the health impacts from flaring and leaks. Socially, gas expansion often results in land grabs, displacement, and increased conflict—ultimately proving to be a wasteful form of development that brings little to no lasting benefit to communities. We must move away from this narrow, top-down approach and instead adopt a development lens rooted in the lived realities and priorities of affected communities.
Any financing by the ADB must therefore ensure it does not extend the lifetime of fossil fuel assets. Public finance should only support projects that are clearly aligned with the goals of the Paris Agreement, including having a near-term, science-based phase-out plan. The burden of mitigating methane leakage or upgrading infrastructure should not fall on public institutions when oil and gas companies are reaping record profits. ADB’s role must be to accelerate the energy transition—not to subsidize the continued viability of fossil fuel operations.
2. Hydrogen and Ammonia Co-Firing – New Faces of Old Fossil Fuels
The proposed allowance for co-firing green hydrogen and ammonia in existing coal and gas plants under paragraph 75 is also of deep concern. These technologies are being promoted as clean, but their production—especially when tied to fossil fuels or dependent on massive water and land resources—poses severe climate and environmental risks. Green ammonia and hydrogen remain largely unproven at scale and are being used to delay the retirement of polluting infrastructure. It should also be noted that green hydrogen requires new electrolyzer innovations that rely on the extraction of scarce resources like platinum, yet lacks transparency on where industrial zones will be located, which communities will bear extraction impacts, labor conditions in manufacturing, or where green hydrogen projects will be sited. These are false solutions that may serve to extend the life of coal and gas assets under the guise of emission reductions.
3. CCUS – A Policy Loophole that Risks Widening
We note the proposed amendment under paragraph 77, which expands the prohibition of CCUS for enhanced oil recovery to include enhanced gas recovery. While this is welcome, we are alarmed by the simultaneous proposal to allow CCUS storage in depleted oil and gas wells.
This creates a dangerous loophole in the policy, effectively keeping the door open to continued use of CCUS—an expensive, unproven, and energy-intensive technology that has not demonstrated real-world climate benefits at scale. Civil society has long warned that CCUS serves to justify continued fossil fuel use while diverting resources from real solutions like solar, wind, and energy efficiency.
4. Energy Transition Mechanism (ETM) Risks – A Backdoor for Gas
ADB’s ETM was presented as a tool for accelerating coal retirement. However, civil society has consistently raised the alarm that it may simply replace coal with gas, trading one fossil fuel for another. The current model of ADB’s ETM over the years has revealed significant flaws, especially in incentivizing coal plant operators without any reparation and transition plans, a threat of a bailout, a fuel switching option instead of decommissioning, a lack of transparency, and weak community engagement. With these existing challenges, it exposes the public's money to the risk of being funneled to the same coal industry. The expansion of its scope to fossil gas and oil, without addressing the structural problems of its existing model, would definitely be a refinancing tool for fossil fuel expansionists.
Vague statements made during the consultations confirmed our fears: ADB is preparing to support gas conversion of ETM-stranded assets. This would contradict the very purpose of the ETM, derail decarbonization efforts, and burden future generations with stranded gas assets.
5. Global Commitments Must Guide ADB’s Policy
ADB and its member countries have legal obligations under the Paris Agreement, Law of the Sea, and customary harm prevention and human rights international law to only finance projects that align with the 1.5°C global warming limitation objective. Supporting any new gas infrastructure—or technologies that prolong fossil fuel dependence—undermines this requirement. Moreover, ADB must uphold its accountability to the Global Methane Pledge made at COP26. Expanding gas, while claiming methane reductions, is a contradiction.
The recent ruling from the International Court of Justice (ICJ) confirmed that the 1.5°C threshold has become the scientifically grounded consensus target under all sources of international law. The ICJ clarified that this global temperature rise limit is not merely aspirational, but an internationally agreed objective that informs and underpins States’ obligations under the Paris Agreement, UNFCCC, Law of the Sea, and customary harm prevention and human rights international law. In parallel, the Inter-American Court of Human Rights (IACtHR), stressed that States must adopt climate measures that are realistically implementable. Such measures must address the sectors responsible for the majority of national GHG emissions, consider the economic costs and benefits of emission reductions, and contribute to the preservation of the global climate system, while aligning with sustainable development goals.
6. ADB’s Role in the Global Energy Divide
As institutions in the Global North move swiftly toward renewable energy for their populations, ADB appears to be enabling a fossil fuel lock-in in the Global South. Why should communities in Asia and the Pacific continue to bear the brunt of dirty, outdated technologies while others benefit from clean energy futures?
Our Demands:
In light of the above, we urge ADB to:
- Explicitly exclude gas from all forms of support—midstream, downstream, or through indirect financing and ETM pathways.
- Reject hydrogen and ammonia co-firing in fossil fuel plants, given their risks and unproven viability.
- Close all CCUS loopholes, including disallowing the use of depleted wells and ensuring no backdoor support for fossil fuel operations.
- Center its energy policy around just, equitable, and renewable-based transitions in line with Paris Agreement goals.
- Engage in meaningful, transparent, and inclusive consultation with civil society, particularly from affected communities in the Global South.
The stakes are high. The choices ADB makes today will shape the energy landscape of the Asia-Pacific region for decades. Let these choices reflect a genuine commitment to climate justice, clean energy, and the rights of people—not the interests of fossil fuel corporations.
Sincerely,
The Big Shift Global Coalition
An international coalition of 50+ civil society organizations