CDM Watch and the Sierra Club respectfully submit the following comments on the Project Design Document (PDD) for Energy Efficient Power Generation by Welspun Energy Anuppur Private Limited (WEAPL). We thank the CDM Executive Board and Designated Operating Entity DOE), Bureau Veritas Certification Holding SAS, for recognizing the integral role of transparency in the CDM validation process, and for taking this comment into consideration.

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 find the comment´s PDF in attachment.