Submission of comments to the DOE/AE
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Compilation of submitted inputs:
This is a project deploying patented FaL-G technology based on which already there are three registered projects [Ref Nos 0707 (Regd under II.D), 4585 and 4831(Regd under III.Z)].
The manufacturing process in this project also do come under this IP. But, as the IP holders are liberal in not invoking the patent in order to facilitate the proliferation of their technology in the interest of its massive contribution to sustainable development, there is no contest on this count.
However, the referred baseline emissions and leakage on account of using biomass at 2% are not fair figures. In this aspect, the conservativeness adopted in the registered projects by taking 5% on account of biomass towards reduction in baseline emission may be taken as bench mark.
Already there is strict internal inspection plan invoked by PP (Eco Carbon Pvt. Ltd - ECPL) of above referred Registered projects. Though III.Z talks about monitoring project emissions based on production, in order to enhance due diligence, the PP (ECPL) monitors the power/diesel consumption and fly ash consumption to justify the production claim. If there is any mismatch, the least tallied data are taken as production. Further, in order to justify the production claim, sales records are also monitored under internal inspection plan. In the process, large amount of counter factual claims were filtered over the last six years. (Prior to Registration, these projects have been verified for VERs under agreement with the World Bank).
Moreover, ECPL apportioned about 12.6% of ER revenue towards community welfare programs, taking the workers of FaL-G brick units as the community, which is strictly monitored by the World Bank. No such program is envisaged in this project.
Submitted by: Bhanumathidas Kalidas
This is a project deploying patented FaL-G technology based on which already there are three registered projects [Ref Nos 0707 (Regd under II.D), 4585 and 4831(Regd under III.Z)].
The manufacturing process in this project also do come under this IP. But, as the IP holders are liberal in not invoking the patent in order to facilitate the proliferation of their technology in the interest of its massive contribution to sustainable development, there is no contest on this count.
However, the referred baseline emissions and leakage on account of using biomass at 2% are not fair figures. In this aspect, the conservativeness adopted in the registered projects by taking 5% on account of biomass towards reduction in baseline emission may be taken as bench mark.
Already there is strict internal inspection plan invoked by PP (Eco Carbon Pvt. Ltd - ECPL) of above referred Registered projects. Though III.Z talks about monitoring project emissions based on production, in order to enhance due diligence, the PP (ECPL) monitors the power/diesel consumption and fly ash consumption to justify the production claim. If there is any mismatch, the least tallied data are taken as production. Further, in order to justify the production claim, sales records are also monitored under internal inspection plan. In the process, large amount of counter factual claims were filtered over the last six years. (Prior to Registration, these projects have been verified for VERs under agreement with the World Bank).
Moreover, ECPL apportioned about 12.6% of ER revenue towards community welfare programs, taking the workers of FaL-G brick units as the community, which is strictly monitored by the World Bank. No such program is envisaged in this project.
Submitted by: Bhanumathidas Kalidas
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