CDM Methodologies AM0028 and AM0034 only deal with N2O destruction. This submission expresses CDM Watch’s serious concerns that there is a perverse incentive to create more N2O than is economically necessary by using a sub-optimal primary gauze that does not minimize N2O formation. Project developers could therefore avoid to install a primary gauze that would minimize the formation of N2O in order to maximize the amount of CERs.