On behalf of CDM Watch, the Stanford Environmental Law Clinic respectfully submits the following comment on the Project Design Document (PDD) for Grid Connected Energy Efficient Power Generation In Jhajjar, Haryana (Project). We thank the CDM Executive Board and Designated Operating Entity (DOE), SIRIM QAS International Sdn. Bhd., for recognizing the integral role of transparency in the CDM validation process, and for taking this comment into consideration.

If approved, this Project could lead to excess issuance of Certified Emissions Reductions (CERs) beyond any actual emissions reductions. Our analysis of the PDD indicates that the DOE must not validate the Project under the ACM0013 methodology.

Please find embedded the comment in PDF.