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Comments and Suggestions for Improvement for methodologies AM0028 and AM0034 on Nitric Acid treatment

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.

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