WWF Denmark finds the PPD insufficient for validation of the project due to lack of documentation in a number of areas. First and foremost, the demonstration of additionally by use of barriers is undocumented and not comprehensive. Secondly, the assessment of the contribution to sustainable development including the approval of the host country is unclear.

Moreover, WWF Denmark finds that the specific location of the project in a vulnerable natural resource area calls for special attention to environmental impacts. In addition to this, the stakeholder consultation has not included people directly impacted by the project or local NGO’s that could have identified negative local impacts. The project therefore has not met a key validation requirement – consultation with affected stakeholders.

Sustainable development criteria

According to the PDD, the project satisfies national sustainable development criteria for small CDM projects in India. There is, however, no documentation for this statement. The letter from the DNA does not refer to any compliance with sustainable development criteria and is thus not sufficient documentation.

The PDD should include a short description of the screening and the applied criteria should be included as an annex to the PDD.

In addition, it should be documented that the resources used for electricity production are in fact waste that is presently left over and that the use in the project is not competing with other waste uses in the local community.

Environmental Impact Assessment

The Sabah region is a vulnerable natural resource area where biodiversity is already under environmental pressure. WWF finds that an EIA should have been carried out in order to ensure that that project does not introduce additional negative impacts.

At the very least, a screening according to international EIA methodologies should have been carried out in order to justify the lack of a full EIA. This is even more appropriate since the public consultation process has not involved people directly affected by the project or local NGO’s that could have identified possible environmental impacts.

Public consultation

The public consultation process has only involved authorities and government agencies. Ensuring appropriate and adequate stakeholder consultation is key to ensuring that the projects bring real sustainability benefits. Local policy makers, local people directly impacted by the project and local NGO’s should be involved. In addition, local public participation is important in the screening of possible negative environmental impacts from projects.

financials submitted to bankers are on 20 MW or 23 MW?

as per MNRE standards we are supposed to use 62 ata boiler pressure as minimum. Th project meets the standards of MNRE, and all the projects in India above 15 MW are using the same technology, the project is not technically additional.