CDM Watch respectfully submits the following comment on the Project Design Document (PDD) for “Thoothukudi Thermal Power Project”, India. 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. We emphasize that, according to our analysis of the PDD, the Project “Thoothukudi Thermal Power Project” must not receive a positive validation under the ACM0013 ver. 4 methodology.

Please find embedded the comment´s PDF.