Information provided in the PDD make the additionality of the project questionable since both, the investment analysis and the common practice analysis raise serious concerns. The investment analysis does not provide credible data since it is based on outdated IRR benchmark of 2002. It is also questionable that the IRR benchmark was used as a key parameter for the investment decision of the project participants since it is not clear whether the project would reach the benchmark even with CDM finance. The common practice analysis provided in the PDD fails to list similar Inner Mongolian Wind power projects, which are published in “The Wind Power” database1. Moreover, the plant load factor which is a key parameter of the investment analysis is not sufficiently justified. The plant load factor used (26%) seems business-as-usual in China and therefore should be discarded form CDM.

The sustainable development benefits appear not to be substantial and are not justified. A rough analysis shows the project does not enhance substantially the local employment as it is claimed. The impact on bird wildlife is ignored even though it usually requires mitigation measures in case of wind projects.

The stakeholder consultation which is a key issue for ensuring sustainability is poorly documented and provides suspect results.

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