CDM Watch and the Sierra Club respectfully submit the following comments on the Project Design Document (PDD) for “Replacement of electricity generated by existing 4 subcritical units of 120 MW of Koradi TPS by 1 unit of 660 MW based on supercritical technology, India.” 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.

If approved, this Project would lead to the issuance of 2,151,840 excess Certified Emissions Reductions (CERs) that do not represent additional emissions reductions, and would give the project participant an undeserved windfall on the order of € 25 million (based on current CER prices). The project activity, as presented in the PDD, is not eligible for validation under ACM0013 ver.4, the Additionality Tool, and other CDM tools and guidelines, for the reasons outlined below.

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