CDM Watch and the Sierra Club respectfully submit the following comments on the Zhejiang Yueqing 2 x 660MW Ultra-supercritical Power Generation Project. We thank the CDM Executive Board and Designated Operating Entity (DOE), China Environmental United Certification Center Co., Ltd., for recognizing the integral role of transparency in the CDM validation process, and for taking this comment into consideration.

According to our research, this project is not additional and should not receive a positive validation. Quite simply, ultra-supercritical technology is already common practice in China, and this project will proceed using ultra-supercritical technology regardless of whether the CDM provides support.