A difficult and persistent issue in the discussion of Clean Development Mechanism is estimating a carbon emissions baseline, against which tradable permits may be certified. This paper examines the proposition of adopting sectoral, as opposed to project level, baselines by conducting case studies of the electricity industry in three Chinese provinces. We find that complicated central planning, financial and institutional factors have been behind the declining trend of carbon intensity in electricity generation and its provincial variations. Government planned electricity development which incorporates many of these factors and the associated industry carbon intensity may serve as a second best baseline. However, the limitation of the baseline we examine in this study plus difficulties numerous studies have revealed in baseline setting suggests that using baselines based on counterfactuals of what would happen will in the end either miss good emission reduction opportunities, or compromise the integrity of the regime. (C) 2003 Elsevier Ltd. All rights reserved.