CDM Watch respectfully submits the following comment on the Project Design Document (PDD) for “Huadian Ningxia Lingwu Phase II 2×1000MW Ultra-Supercritical Power Generation Project”, China. We highlight the importance of recognizing the integral role of transparency in the CDM validation process, and for taking this comment into consideration.

We believe that this project is not additional and if approved, will lead to excess issuance of Certified Emissions Reductions (CER’s) beyond any actual emissions reduction. Using CDM funds to lock-in 20 years of coal mining and combustion and the associated adverse impacts on the land, water, air, climate, and human health and welfare undermines sustainable development and will ultimately make it more difficult for both developed and developing countries to meet GHG emission reduction targets that are necessary to avert the worst impacts of global climate change. We emphasize that according our analysis of the PDD the Project ““Huadian Ningxia Lingwu Phase II 2×1000MW Ultra-Supercritical Power Generation Project” must not receive a positive validation under the ACM0013 ver. 4 methodology.

Please find embedded the comment in PDF.