Waste gas usage in cement manufacturing unit in Andhra Pradesh
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Host party(ies) India
Methodology(ies) AMS-III.Q. ver. 4
Standardised Baselines N/A
Estimated annual reductions* 6,512
Start date of first crediting period. 01 Mar 12
Length of first crediting period. 10 years
DOE/AE TÜV NORD CERT GmbH
Period for comments 05 Sep 11 - 04 Oct 11
PP(s) for which DOE have a contractual obligation The India Cements Limited
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (797 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs: 
The Board, at its forty-first meeting considered a draft proposal prepared by the Methodologies Panel on the enhanced barrier test for project activities that have a potential for high profitability without CER revenues and only use a barrier analysis to demonstrate additionality. This project exactly fits into the concern expressed by EB. This project is not additional. Additionality cannot be demonstrated with financial analysis as the IRR of the project will be in excess of 20%. PP would have set up the project with or without CDM benefits. Therefore, the PP has selected barrier analysis. Several cement manufacturing units have been manufacturing pazzalona cement and none of them have faced this problem which the PP is apprehending. Even assuming that the project faces the barrier, as per Annex 13, EB 50, it should be quantified. 

Accepting technological barrier for additionality demonstration is not conforming to the EB’s concern and not appropriate
Submitted by: Karthikeyan

The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs