On behalf of CDM Watch, the Stanford Environmental Law Clinic respectfully submits the following comment on the Project Design Document (PDD) for the Shanghai Caojing 2x1000MW 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 validation process, and for taking this comment into consideration.

If approved, this Project could lead to excess issuance of Certified Emissions Reductions (CERs) beyond any actual emissions reductions. Our analysis of the PDD indicates that the DOE must not validate the Project under the ACM0013 methodology for the reasons outlined below.

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