"I am resubmitting my comments as the file I had uploaded could not be opened by DOE"	

1.    Section  B.2. Justification of the applicability of the baseline and monitoring methodology to the proposed small-scale A/R CDM project activity:

"a)	Reforestation will take place on what was cropland prior to the project activity. The project area consists entirely of fallow savoka that was previously under cropland management and is currently heavily degraded fallow that will not return to natural forest without human intervention."

Comment: As I presume from the PDD, the project is being developed on degraded land abandoned after unsustainable shifting cultivation practices. The project sites are located on the margin of forests as apparent from Figure 12 in the PDD. Under such conditions is it appropriate to assume that natural forest would not have encroached on the land in the absence of the reforestation project? 

Whilst it has been justified in Section A.7 (page 37 of PDD), it has been described that the entire area is overrun with invasive species like Lantana and Clidemia, data from sample plots shows that Psiadia altissima, a naturally occurring shrub which is a common indicator of natural succession in fallow lands, is encountered in 32% of the total sample. Hence under such conditions it is not implausible to say that there will be natural regeneration and encroachment of natural forests from adjoining areas won’t happen in the absence of the project activity. 

"b)	There is no cropland displacement due to the implementation of the project activity: The plots proposed wered voluntarily by farmers for the project activity are heavily degraded areas of savoka. These parcels constitute unproductive areas that they no longer use."

Comment: Whilst it is being argued in Section B. 2., that the project is being established on abandoned land, from the discussion in B. 6., the impression is that the project area is under very short cycles of fallow-cropping. If such was the conditions historically but now the land parcels have been permanently abandoned, the arguments for justifying the baseline scenario viz. points 1-3 (page 45 of the PDD) are misplaced. If the land remains permanently abandoned as envisaged in the baseline scenario, there is no question of disruption of vegetation succession by fire as envisaged in point 4-5 of the baseline scenario (page 45-46 of the PDD), there is a very high chance of encroachment by adjoining forests unto the land in the absence of the project activity. But if there is a chance of the land being cropped again due to under shifting cultivation, displacement of agricultural activities should be taken into account in the baseline scenario. 

2.	Section B7. Description of how the actual net GHG removals by sinks are increased above those that would have occurred in the absence of the registered small-scale A/R CDM project activity:

"Institutional barriers: The CDM component of the project means that reforestation becomes a viable, income generating land use for local actors and should allow these institutional barriers to be overcome."

Comment: More than 60% of the project area is government land, which is managed by different facilitating agencies (FAs) that have legal right to the tCERs from the project. As the FAs who are undertaking the project implementation on government lands have been engaged through management contract by the concerned government agency, the question about lack of viability of the project activity from the point of view of FAs does not arise.