In section A.5.4, it is stated that chemical fertilizers are being applied; however, the type of chemical fertilizers and its quantities as well as its frequency have not been stated in the PDD. On the other hand, we feel a scope of methane emission from the rice straw too. Same is the probability while preparing a 0.04 x 0.04 x 0.04 meter pits.  In these circumstances, the claim made in section A.5.5 that “there are no potential leakage emissions attributable to the proposed A/R project activity needs to be revisited. 
In section A.8 of the PDD, it is stated the project activity would consider t-CERs, where as in section B.3.2, the PDD said that the length of fixed crediting period is 30 years. Both these statements are contradictory in nature, as 5/CMP.1, Annex, paragraph 1: states that "Temporary CER" or "tCER" is a CER issued to project participants in an afforestation or reforestation project activity under the CDM which, subject to the provisions of section K below, expires at the end of the commitment period following the one in which they are issued (5/CMP.1, Annex, paragraph 1(g)). 
Therefore, tCERs differ from long-term certified emission reductions (lCERs) in that tCERs expire at the end of the commitment period in which they were issued, while lCERs expire at the end of the crediting period for the project. This also presents us a scenario, where the project proponent must make it clear that when the baseline will be re-estimated by considering the temporary crediting period. 


Yours sincerely, 

Keshav C Das
Regional Director
CTG Advisory Services India Pvt Ltd
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