CDM Watch and the Sierra Club respectfully submit the following comments on the Project Design Document (PDD) for Energy efficient power generation in Raigarh, Chhattisgarh, India. We thank the CDM Executive Board and Designated Operating Entity (DOE), SGS United Kingdom Limited, for recognizing the integral role of transparency in the CDM validation process, and for taking this comment into consideration.
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.