On behalf of CDM Watch, the Stanford Environmental Law Clinic respectfully submits the following comment on the Project Design Document (PDD) for the Jiangxi Xinchang 2x660MW Ultra-Supercritical Project (Project). 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 …
Read more “Comments on Validation of Xangxi Xinchang 2×660MW Ultra-Supercritical Project, China”
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.
We would like to raise several serious concerns about the validation of Zhejiang Guodian Beilun Ultra-supercritical Power Project. This specific project does not meet the requirements of the CDM for a number of reasons and should not be positively validated.
CDM Watch unsolicited letter insisting the CDM EB to include NGOs numerous requests for revision of the baseline and monitoring methodology AM0001 for HFC-23 destruction in EB meeting agendas.
