Municipal Solid Waste Processing project -Project1
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Host party(ies) India
Methodology(ies) AM0025 ver. 13
Standardised Baselines N/A
Estimated annual reductions* 59,167
Start date of first crediting period. 01 May 12
Length of first crediting period. 10 years
DOE/AE Bureau Veritas India Pvt. Ltd.
Period for comments 04 Feb 12 - 04 Mar 12
PP(s) for which DOE have a contractual obligation Bunge Emissions Holdings SARL
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 (1051 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
1.	First and foremost, the composition of waste has not been mentioned. This data would be surely available or a feasibility study for RDF technology would have been incomplete without a survey/research into percentage composition various individual waste streams. Weight-wise distribution of various MSW components also needs to be well researched to indicate the CV of the RDF post treatment.
2.	What is percentage wise content of Municipal Solid Waste received by Hanjer Biotech for processing? Whether Municipal Corporation will treat the waste in any manner before transportation?
3.	What is frequency of road transportation carrying MSW from collection point to site? Whether transportation emission has been considered?
4.	RDF pelletes will be sold to near by industries as alternative fuel. What is content of emission of these pelletes?
5.	Are there any financial benefits for surrounding villages due to proposed CDM project of Hanjer Biotech as a part of Corporate Social Responsibility? Whether company has proposed any community welfare projects in benefits of surrounding community
6.	specific chemical is used to accelerate biological decomposition? Such information would be valuable for students as well as general public.
7.	Unwanted materials including inert rejected during processing are either recycled in the plant or properly taken out as segregated items for their utilization as raw materials to other recycling industries. In short, integrated inert management is an important feature of the plant.” Does this mean it is a zero-discharge plant? How is it possible to recycle paper shreds, plastic wrappers and polythene bags, bottle caps which are not of grades I to VI and suitable for recycling? What about the inert debris, sand dust, stones, floor sweepings, ash? In the present form the PDD suggests that absolutely nothing is taken to the landfills, which would mean that all of the above might be dumped in the surrounding areas. PDD mentions about a dump yard. Is it a designated dump yard or yet another open landfill? 
8.	Furthermore, it is not clear whether the boilers or kilns, which are meant to receive RDF, belong to HBEPL or not. There is also no mention of the type of industry to which the RDF will be supplied and the baseline fuel for such industry types. It may be that the normal practice for such industry is use of Natural gas, which can be less incumbent upon the environment than the combustion of RDF.
9.	Financial barriers are not described at all and are left to the readers’ imagination. IRR figures seem to be random numbers. There is also no mention of the MNES and other such nodal agencies encouraging investments into such technologies through Public private partnerships and the subsidies that these projects can acquire.
10.	“There is no mechanical facility provided other than screening machine which cannot separate wet and dry waste for segregation of MSW. Because of the very high cost of facilities for the sorting, separation and recycling of waste, it is uneconomical for the project participants.”
This argument placed under technological barrier is out of context and meaningless. Earlier, in the PDD, the text preceding the diagram describes the various sorting processes that have been incorporated to produce a uniform and high CV MSW stream. What was that about then? If any of the necessary technological inputs are deemed “uneconomical”, they need to be specified under financial barriers and appropriate replacements for such inputs should be in place. Else, the entire credibility of the project in terms of it resulting into net social, environmental and technological benefits is highly questionable. 
Furthermore, the discussion mentions the Indian municipalities’ inability to comply with MSW 2000 rules on various grounds. These are not the barriers related to the project. Again the arguments are out of context and weak. 
11.	The whole additionally argument collapses because of the fact that there is no mention of the alternatives available to the project. There are other forms of MSW treatment, which are environmentally far more positive such as vermi-composting, which require far lesser technological input and avoid GHG emissions at the same time. Biological forms of treatment are cheaper and better researched for Indian MSW. Finally, for a common man, it would seem that the option of constructing sanitary landfills, with methane recovery and combustion, should be given a greater preference rather than such short term fixes. Although, RDF may still be justifiable, but needs strong justifications and as such should be benchmarked against other forms of MSW treatments. 
12.	Sub-step 2b: Option III. Apply benchmark analysis is like magic figure no any actual calculation 
13.	Section : E The Stakeholders were invited for the meeting by sending invitation letters on 1st February 2010 for Pune, Junagadh and Vadodara. The objective of the meeting was to conduct open discussion where stakeholders are encouraged to raise questions, express their concern and comments about the proposed project through a participatory process they have not mention that how many question is raised 
14.	At present company develop greenbelt at processing plant Pune-Junagadh & Vadodara location ?
15.	This company not required EIA! Who is controlling authority for pollution 

Overall, the PDD lacks many of the most basic details and is less than half complete. Some sections of the PDD have been quoted verbatim from similar a successful CDM project, which makes me doubt the entire integrity of the rationale behind such a project
Submitted by: Shailenndrasinh Jadeja

Comment (543 KB) submitted by: Shailenndrasinh Jadeja on behalf of Shailendrasinh Jadeja

Comment (43 KB) submitted by: Shailenndrasinh Jadeja on behalf of Shailendrasinh Jadeja

Comment (43 KB) submitted by: Shailenndrasinh Jadeja on behalf of Shailendrasinh Jadeja

Purely Dirty secret for getting Carbon Credit to sale 
Submitted by: Shailenndrasinh Jadeja

(i)	Infrastructure facilities are lacking, 
(ii)	Not Mention installation of pollution control equipments
(iii)	Regularly Unauthorized burring of solid waste instead of making fuel pellets
(iv)	Not Mention about MSW landfill site not being developed at all
(v)	No Plantation of trees and no green belt developed all
(vi)	No control measures for dusting resulting from handling of solid waste exists-severe dust pollution and very untolerable bad smell. Day to day garbage is being dumped on near by land & road also.Proper leaches facility not available
Submitted by: Shailenndrasinh Jadeja

1.Why Company not give any advertisement for this project in any leading news paper for any publicity?
2.Company said that invitation letter sent to stakeholder but they not mention that how many invitation letter sent?
3.Company said that environment friendly project who decide that this project is environment friendly?
4.every place only three person present?
Submitted by: Shailenndrasinh Jadeja

Comment (43 KB) Submitted by: Shailendra Kumar Shukla

Comment (543 KB) submitted by: Shailenndrasinh Jadeja on behalf of Tikubhai

We are totally oppose to give Permission for give any permission like this type of Hazardous Unit
Submitted by: Shailenndrasinh Jadeja

Comment (327 KB) Submitted by: Shailendra Kumar Shukla

Do send some auditors who are not in the business development and marketing with the PP. Bureau Veritas should depute a team for any audit who is not involved in the marketing with the client. Bureau Veritas now a days is doing CDM audits in very short time and giving reports. Why and how? What has changed? Overnight have they become very knowledgeable? Same people, same systems and their attitude towards CDM validation has changed and BV auditors are giving request for registration without checking the full particulars of the project. Why the sudden change in attitude? Auditors want to milk CDM and spoil CDM system and then go for their regular inspection and ISO certification stuff when CDM dies? Because of DOE’s like this only CDM is going to dogs. Auditors like HB Muralidhara, Sanjay Patankar and other likeminded auditors in BV are going very fast on CDM projects of their choice and certifying in a great hurry. Why? Bureau Veritas management should probe this? If BV management does not take real interest and keep the house in order, UNFCCC should check this issue. Why BV’s all old projects which are published for comments in 2007 and 2008 are getting request for registration all of a sudden? What clients have shown and given off late which they have not done in the last 3 years or so? What is this? What is happening? What kind of TR is being done? Is TR done just for the sake of doing or is TR raising any true and genuine issues? HB Muralidhara and Sanjay Patankar should not be used for any large scale projects as LA as their independence is definitely questionable. They should be used only for TR and some “independent and new to consultants and large group companies” auditors to be used as LA’s. At least both of them should be sent to Inspection to save BV’s reputation on CDM business. BV auditors relationship with some of the big group of companies in India & other countries and some consultants is questionable and brings disrepute to CDM process. Names need not be written, everyone knows including BV’s management. If no credible corrective actions are initiated immediately by BV’s management then we have no other option except to come out openly with names of companies and consultants with whom BV is involved in wrong activities. How come HB Muralidhara and Sanjay Patankar do audits for clients and consultants when both are doing marketing and seeking business from market? Is this allowed in any third party certification business? Why BV is flouting rules, for disgrace? Why BV’s auditors themselves are giving suggestions how to close CAR’s and CL’s for CDM projects? Why they are advising corrective actions? Is it acceptable? BV’s management and UNFCCC should look into this matter and correct the things immediately in the interest of CDM process. Flavio Gomes is fit for counting revenues and does not have a proper oversight on his own business operations area, which is proven effectively now. It’s time to set the business in order. Copy marked to UNFCCC. 
Submitted by: M.Brutus

Do send some auditors who are not in the business development and marketing with the PP. Bureau Veritas should depute a team for any audit who is not involved in the marketing with the client. Bureau Veritas now a days is doing CDM audits in very short time and giving reports. Why and how? What has changed? Overnight have they become very knowledgeable? Same people, same systems and their attitude towards CDM validation has changed and BV auditors are giving request for registration without checking the full particulars of the project. Why the sudden change in attitude? Auditors want to milk CDM and spoil CDM system and then go for their regular inspection and ISO certification stuff when CDM dies? Because of DOE’s like this only CDM is going to dogs. Auditors like HB Muralidhara, Sanjay Patankar and other likeminded auditors in BV are going very fast on CDM projects of their choice and certifying in a great hurry. Why? Bureau Veritas management should probe this? If BV management does not take real interest and keep the house in order, UNFCCC should check this issue. Why BV’s all old projects which are published for comments in 2007 and 2008 are getting request for registration all of a sudden? What clients have shown and given off late which they have not done in the last 3 years or so? What is this? What is happening? What kind of TR is being done? Is TR done just for the sake of doing or is TR raising any true and genuine issues? HB Muralidhara and Sanjay Patankar should not be used for any large scale projects as LA as their independence is definitely questionable. They should be used only for TR and some “independent and new to consultants and large group companies” auditors to be used as LA’s. At least both of them should be sent to Inspection to save BV’s reputation on CDM business. BV auditors relationship with some of the big group of companies in India & other countries and some consultants is questionable and brings disrepute to CDM process. Names need not be written, everyone knows including BV’s management. If no credible corrective actions are initiated immediately by BV’s management then we have no other option except to come out openly with names of companies and consultants with whom BV is involved in wrong activities. How come HB Muralidhara and Sanjay Patankar do audits for clients and consultants when both are doing marketing and seeking business from market? Is this allowed in any third party certification business? Why BV is flouting rules, for disgrace? Why BV’s auditors themselves are giving suggestions how to close CAR’s and CL’s for CDM projects? Why they are advising corrective actions? Is it acceptable? BV’s management and UNFCCC should look into this matter and correct the things immediately in the interest of CDM process. Flavio Gomes is fit for counting revenues and does not have a proper oversight on his own business operations area, which is proven effectively now. It’s time to set the business in order. Copy marked to UNFCCC. 
Submitted by: M.Brutus


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