Section A.2: As per the guidance and clarifications relating to the Project Design Documents (PDD), EB.42, Version09, Annex. 12, the project proponent must demonstrate in section A.2 about the potentiality of the proposed project on sustainable development. Merely, making a statement that ‘The A/R project is a human induced natural regeneration on degraded lands and erosion prone areas to improve soil stabilization and soil fertility…and project activity would generate more income opportunities for the farmers of the land on long term’ is not sufficient. Therefore, project participants are requested to make a qualitative (quantitative) description of the most probable trans-boundary and project-related development benefits of the project, which could be percolated down to the stakeholders.  

Section A 4.2: There is no such section in the PDD format, designed for AR CDM project. This section should be A.4.1.4. As per the guidelines, this section shall depict the unique geographical identification for each discrete area of land. The boundary should be defined for each discrete area and should not include the areas in between these discrete areas of land. But, it is found that the PDD has not lined any such specification (which is a part of completeness check of the PDD), contrary to which the project proponent has put a few web-based map which are redundant. 

Section 5.2: The description of climate, hydrology, soils and ecosystems are very general and many often focused on the macro scenario of the states. As per the requirement of the PDD it should be project specific and micro in nature which could have a direct or indirect correlation with the proposed project activity. Moreover, these descriptions shall be based on soil testing report, metrological data (primary or secondary). The PDD has not taken care of this issue. 

Section A. 5.2. It is not clear whether the long list of rare or endangered species and their habitats are prevailing in the project area? I request clarification. 

Section A.5.6. It is stated that the project did not cause significant leakage. This statement is not consistently convincing owing to the description of the PDD in section A. 5.4, where it was lined that fertilizer application, tillage operations with mechanized techniques and ploughs were practiced. There are also possibilities of emission of methane from the rice straw. 

Section A.7: The justification on eligibility of land is ambiguous. PDD says that ‘…..neither covered by young natural stands or plantations with the potential to reach the national forest threshold’ which implies that there were some vegetations. Can the project developer name it with details? The argument on ‘the land is under ongoing process of degradation’ has to be further illustrated. This must also have to be supported by revenue maps/satellite imageries as well as PRA report. In addition, the project developer should also define the ‘state of the land’ before the project activity to prove that the area (for each parcel) is eligible for reforestation. 

Section B.1: The project start date is 24/04/2001. Can the project developer provide proof for ‘serious and continuous’ efforts? Why the project was not started on 2004 or 2005/2006, and took so much time? 

In PDD, once the project developer has used the term waste land and in another page the area is termed as degraded land (While describing about the methodology). Please clarify. 

Section C.2: Justifications on applicability conditions are wooly. Please provide us more information on the encroachment, shift of activity etc.

C.6: The project should use Combined tool to identify the baseline scenario and demonstrate additionality, not what the PDD has used?  Please clarify on the financial estimation.
Monitoring plan needs more specification and administrative structure.
Keshav C Das
Regional Director, Business Operation
CTG Advisory Services India Pvt. Ltd
Clean Trade Group
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