Carbon Market Watch

For fair and effective climate protection.

Public comments on CDM projects under validation

Comments on Validation of Thermal power generation using less GHG intensive technology, India

According to our research, this project should not receive a positive validation because it is not additional nor did it apply the correct baseline scenario. Quite simply, this project will use supercritical technology regardless of whether the CDM provides support. more »






Comments on Validation of GHG Emission reductions through power generation at high efficiency, India

According to our research, this project should not receive a positive validation because it is not additional nor did it apply the correct baseline scenario. Quite simply, this project will use supercritical technology regardless of whether the CDM provides support. more »











Comments on Validation of Energy Efficiency Power Generation by Welspun Energy Madhya Pradesh Limited

According to our analysis, this project should not be validated because it is not additional and did not apply the correct baseline scenario. Quite simply, this project will use supercritical technology regardless of whether the CDM provides support. more »











Comments on Validation of Energy Efficiency Power Generation by Welspun Energy Anuppur Private Limited, India

According to our analysis, this project should not receive be validated because it is not additional and did not apply the correct baseline scenario. Quite simply, this project will use supercritical technology regardless of whether the CDM provides support.

Please see PDF file attached. more »











Comments on Validation of Energy Efficient Power Generation by DB Power (Madhya Pradesh) Limited – Phase I, India

According to our research, this project should not receive a positive validation because it is not additional nor did it apply the correct baseline scenario. Quite simply, this project will use supercritical technology regardless of whether the CDM provides support. more »











Request for review of the Additionality of the CDM Project 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology – Jharkhand Integrated Power, Ltd., India

Request for review of the Additionality of the CDM Project 4629: Greenhouse Gas Emission Reductions Through Super Critical Technology – Jharkhand Integrated Power, Ltd., India Unsolicited letter sent on 17 June: download pdf Response letter sent on 22 December 2011: download pdf






Comments on Validation of GHG Emission Reductions through grid connected high efficiency power generation, Coastal Gujarat Power Ltd., India

This project is not appropriate for validation for three reasons. First, the project will generate at least 22 million tons of carbon dioxide pollution per year, and is likely to be the largest single source of emissions in India.1 CDM support for such a high-polluting project is contrary to the overarching objectives of the CDM. Second, it is plainly non-additional and ineligible for support under CDM rules. Quite simply, this project will be completed using supercritical technology regardless of whether the CDM provides support. Third, the Executive Board has previously rejected this project for registration, and the PDD presents no compelling evidence for the validator to disregard the Executive Board’s original conclusion and issue a positive validation this time around. more »











Comments on Validation of Replacement of electricity generated by existing 4 subcritical units of 120 MW of Koradi TPS by 1 unit of 660 MW based on supercritical technology, India

If approved, this Project would lead to the issuance of 2,151,840 excess Certified Emissions Reductions (CERs) that do not represent additional emissions reductions, and would give the project participant an undeserved windfall on the order of € 25 million (based on current CER prices). The project activity, as presented in the PDD, is not eligible for validation under ACM0013 ver.4, the Additionality Tool, and other CDM tools and guidelines, for the reasons outlined below. more »











Comments on Validation of Thoothukudi Thermal Power Project, India

We believe that this project is not additional and if approved, will lead to excess issuance of Certified Emissions Reductions (CER’s) beyond any actual emissions reduction. We emphasize that, according to our analysis of the PDD, the Project “Thoothukudi Thermal Power Project” must not receive a positive validation under the ACM0013 ver. 4 methodology. more »











Comments on Validation of Huadian Ningxia Lingwu Phase II 2×1000MW Ultra-Supercritical Power Generation Project, China

We believe that this project is not additional and if approved, will lead to excess issuance of Certified Emissions Reductions (CER’s) beyond any actual emissions reduction. Using CDM funds to lock-in 20 years of coal mining and combustion and the associated adverse impacts on the land, water, air, climate, and human health and welfare undermines sustainable development and will ultimately make it more difficult for both developed and developing countries to meet GHG emission reduction targets that are necessary to avert the worst impacts of global climate change. We emphasize that according our analysis of the PDD the Project ““Huadian Ningxia Lingwu Phase II 2×1000MW Ultra-Supercritical Power Generation Project” must not receive a positive validation under the ACM0013 ver. 4 methodology. more »