Unsolicited letter to highlight significant concerns about the lack of transparency under the current CDM procedures, in particular to the lack of disclosure of unsolicited letters and letters of approval (LoAs) by Annex I countries that purchase credits from unilateral projects. Request on 7 May 2010: download pdf file Response on 22 June 2010: download …
Read more “Unsolicited Letter: Request on transparency about Unsolicited Letters and LoAs.”
Letter to the CDM EB from CDM Watch on behalf of civil society affected by CDM projects, to highlight significant concerns about effective means for public participation under the current CDM procedures.
Based on reading of the Project Design Document dated March 2, 2010 (version 1 as available on the UNFCCC website) for the above project, having seen the order of Maharashtra Electricity Regulatory Commission on the application of approval of the PPA of MSEDCL with the Project Proponent (PP), having seen the concurrence letter dated Dec 27, 2006 from the Central Electricity Authority (CEA) of Govt of India (GoI) under the section 8 Electricity Act of 2003, having seen the Environment Impact Assessment and also the clearance letter from the Ministry of Environment and Forests (MEF) and having monitored India’s power sector and this project over the last few years we reach the conclusion that it will not be appropriate to accept the project for CDM credits.
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 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.
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.
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.
