Baseline
Open lagoon that has been described in the PDD as the baseline is not allowed in India. This fact can be checked by the DOE by interviewing the pollution control board representative. The project proponent and consultant are only trying to hide the facts about the baseline scenario.
The project proponent has mentioned in the PDD that the "“In normal course distilleries in India adopt open lagoons treatment system for meeting the requirement
of the pollution control standards of BOD/COD of the spent-wash before its discharge”.
Although pollution control board prescribes the discharge limit it does not allow to treat the spenwash through open lagoon system in any of the distillery unit and the same scenario was there during the year 2006. The statement mentioned by the project proponent about the open lagoon option does not have a basis. Either ABGSPL and ILFS are trying to develop a project activity under CDM which is not a CDM project or ILFS does not have a basic understanding about the distillery units. We would advice ILFS to check the facts about the open lagoon option from PCB and would request you to look into CREP for distillery units for more understanding. The CREP was published during the year 2003 and you can get the information from many websites. 
As  per the CREP, The distillery unit could choose the treatment measures like (1) compost making with press mud/agricultural residue/municipal waste (2) concentration and drying/incineration (3)treatment of spent wash through biomethanation followed by two stage secondary treatment and dilution of the treated effluent with process water for irrigation.” However, CREP does not mention any option of treating the  This can be clarified from the central and state pollution control board. In the page 13 of the hosted PDD the PP has mentioned that “In the absence of the project activity, the wastewater from the distillery would have been discharged in the open lagoons without any biogas recovery.” and the PP has mentioned the source as “Environmental Clearance from the Ministry of Environment & Forests dated 23 February 2007”.

We don’t have access to the EC document for the project activity. However, We are confident that EC document will never mention anything on open lagoon treatment option.
It appears that the project proponent and its consultants are trying to misrepresent CREP norms. 

EC generally states that the treated effluent from the unit has to be within the stipulated norms under the EPA rules or State pollution control Board whichever is more stringent. Even if a distillery unit can achive stipulated norms within lagoon it cant treat the effluentin open lagoon in the present scenario and during the year 2006.

Even if EC says only about stipulated norms that does not mean that the project proponent can have open lagoon treatment option.

We would also like to inform you that all the PCB consent states that "as per the CPCB recommendation storage of effluent should not exceed 30 days ". I hope the PP consent must be having this statement.   This can be confirmed from consent under water act .  If you will look into the methodology ACM 0014, the methodology ACM0014 applicability condition specifies that “the residence time of the organic matter in the open lagoon system should be at least 30 days”. 
Although this statement has not been there in AMS IIIH , the statement indicates that only if effleunt will be stored for more than 30 days then it will qualify as open lagoon system.
Therefore,  the open lagoon treatment option argument as a baseline is vague and false.

As per “Combined tool to identify the baseline scenario and demonstrate additionality”(Version 02.2)Step 1a: Define alternative scenarios to the proposed CDM project activity paragraph 3 &4 states that "For the purpose of identifying relevant alternative scenarios, provide an overview of other technologies or practices that provide outputs or services (e.g. electricity, heat or cement) with comparable quality, properties and application areas as the proposed CDM project activity and that have been implemented previously or are currently underway in the relevant geographical area. The relevant geographical area should in principle be the host country of the proposed CDM project activity. A region within the country could be the relevant geographical area if the framework conditions vary significantly within the country.

However, the relevant geographical area should include preferably ten facilities (or projects) that provide outputs or services with comparable quality, properties and application areas as the proposed CDM project activity."
We would request the PP  to include ten facilities and justify the open lagoon treatment option for other 10 facilities in the region. We are sure that the PP will not get a single facility which will treat the spentwash in the open lagoon system.


Finally, we would like to say that open lagoon in the distillery sector cant be justified.  Please dont fool the world body by bringning this kind of project activity under the CDM .