On behalf of CDM-Watch, the Stanford Environmental Law Clinic respectfully submits the following comment on the Project Design Document (PDD) for the Anhui Wenergy Tongling 1000 MW Ultra-Supercritical Coal-Fired Power Project (Project). We thank the CDM Executive Board and designated operating entity (DOE), Bureau Veritas Group, for recognizing the integral role of transparency in the CDM registration process, and for taking this comment into consideration.
Our analysis of the PDD indicates that the DOE cannot validate the Project under the ACM0013 methodology for the reasons as outlined below. If approved, this Project could lead to excess issuance of CERs beyond any actual emissions reductions.
