CDM Watch and the Sierra Club respectfully submit the following comments on the Project Design Document (PDD) for GHG Emission Reductions through grid connected high efficiency power generation. 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.

This project is not appropriate for validation for three reasons. First, the project will generate at least 22 million tons of carbon dioxide pollution per year, and is likely to be the largest single source of emissions in India.1 CDM support for such a high-polluting project is contrary to the overarching objectives of the CDM. Second, it is plainly non-additional and ineligible for support under CDM rules. Quite simply, this project will be completed using supercritical technology regardless of whether the CDM provides support. Third, the Executive Board has previously rejected this project for registration, and the PDD presents no compelling evidence for the validator to disregard the Executive Board’s original conclusion and issue a positive validation this time around.

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