Reforestation as Renewable Source of Wood Supplies for Industrial Use in Brazil
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Host party(ies) Brazil
Methodology(ies) AR-AM0005
Standardised Baselines N/A
Estimated annual reductions* 75,783
Start date of first crediting period. 10 Nov 00
Length of first crediting period. 30 years
DOE/AE TÜV SÜD South Asia Private Limited
Period for comments 14 Apr 10 - 28 May 10
PP(s) for which DOE have a contractual obligation International Bank for Reconstruction and Development as a Trustee of the Prototype Carbon Fund
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 (5282 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs: 
Dear sirs

How can TÜV SÜD Industrie Service GmbH webhost a PDD if it is still suspended by the CDM-EB? Is this in accordance to the CDM rules? Have the CDM validation been contracted prior to the suspension? 
I do not think it is fair to consider that in the absence of the project activity the iron making plants would switch iron reduction from charcoal to coal as this would be completely unfeasible. Moreover, based on information available in the international press, the Brazilian government is strongly combating deforestation of native forests for charcoal production (mainly used for the iron and steel making supply chain). Moreover, environmental regulations in Brazil are known for being strict. That means that medium and large iron making plants are supposed to use charcoal from planted forests (like the proposed project activity) anyway (regardless of CDM incentives).  Thus the project is completely not additional.  If this project ends up being registered this will mean that iron making supply chain will start to be compensated with carbon credits just for being in accordance with the applicable legislation. I do not think that CDM was designed to create incentive to project participants to follow the applicable environmental legislation, as they are supposed to do it anyway (according to applicable Brazilian environmental legislation) 

Chatrapati Smarak Shivaji 
Madras School of Economics 
Chennai, India
shivaji_mse@hotmail.com
Submitted by: Chatrapati Smarak Shivaji
Submitted by: Chatrapati Smarak Shivaji 
Dear sirs

How can TÜV SÜD Industrie Service GmbH webhost a PDD if it is still suspended by the CDM-EB? Is this in accordance to the CDM rules? Have the CDM validation been contracted prior to the suspension? 
I do not think it is fair to consider that in the absence of the project activity the iron making plants would switch iron reduction from charcoal to coal as this would be completely unfeasible. Moreover, based on information available in the international press, the Brazilian government is strongly combating deforestation of native forests for charcoal production (mainly used for the iron and steel making supply chain). Moreover, environmental regulations in Brazil are known for being strict. That means that medium and large iron making plants are supposed to use charcoal from planted forests (like the proposed project activity) anyway (regardless of CDM incentives).  Thus the project is completely not additional.  If this project ends up being registered this will mean that iron making supply chain will start to be compensated with carbon credits just for being in accordance with the applicable legislation. I do not think that CDM was designed to create incentive to project participants to follow the applicable environmental legislation, as they are supposed to do it anyway (according to applicable Brazilian environmental legislation) 

Chatrapati Smarak Shivaji 
Madras School of Economics 
Chennai, India
shivaji_mse@hotmail.com
Submitted by: Chatrapati Smarak Shivaji
Comment (50 KB) submitted by: Klemens Laschefski on behalf of Klemens Laschefski
Comment (105 KB) Submitted by: Jutta Kill, FERN
Comment (93 KB) submitted by: Wolfgang Kuhlmann on behalf of Wolfgang Kuhlmann, ARA
Comment (50 KB) submitted by: carbon trade watch on behalf of Carbon Trade Watch
Comment (50 KB) Submitted by: Ekologistak Martxan
Comment (137 KB) submitted by: Marc Masmiquel Mendiara on behalf of Marc Masmiquel
Comment (103 KB) submitted by: FASE/ES on behalf of 2010.05-Carta Plantar Projeto MDL
Comment (104 KB) submitted by: FASE NACIONAL on behalf of 2010.05 - Carta Plantar Projeto MDL
Comment (56 KB) submitted by: World Rainforest Movement on behalf of Movimento Mundial pelas Florestas Tropicais

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