JI project “Waste coal processing in Luhansk region of Ukraine with the Aim of Reducing Greenhouse Gases Emissions into the Atmosphere (under track 2)”
The definition of the physical project boundaries are not precise and specific enough. Section B.3 says that “The project activities are physically limited to the waste heaps in the legal use of SLAVUTICH MChTPP”. However, it is not specified which waste heaps are in the legal use of Slavutich MChTPP. Moreover, Section A.4.1. states that “During the monitoring period other waste heaps can be acquired and new beneficiation complexes can be put into operation. Data on new objects will be included in the appropriate monitoring reports”. This leaves the project boundaries insufficiently defined and would enable the addition of new facilities. While this would be acceptable under a Programme of Activities, the number of facilities in a conventional JI project must be clearly defined at the onset of the project.
Given the serious concerns we have highlighted in this letter, we hope that you will scrutinize this project sufficiently before making any final decisions or recommendations.