is this project had been validated by SGS? Then why pp change the DOE?

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Comments on the validation of
Zhejiang Guodian Beilun Ultra-supercritical Power Project
We would like to raise several serious concerns about the validation of Zhejiang Guodian Beilun
Ultra-supercritical Power Project. This specific project does not meet the requirements of the
CDM for a number of reasons and should not be positively validated.
The Zhejiang Guodian Beilun Ultra-supercritical Power Project, which “comprises the installation
of two sets of 1000MW ultra-supercritical units of coal-fired generation,” is an inappropriate
project for the Clean Development Mechanism. The mitigation objective of the international
climate change regime requires that societies and economies make a major and rapid transition
to low-carbon bases. This means that we need to figure out how to leave fossil fuels in the
ground and stop extracting them as soon as possible. Construction of a new coal-fired power
plant is inconsistent with this objective.
This project is also manifestly not sustainable development. Kyoto Protocol Article 12(2) clarifies
that a purpose of CDM is to assist developing countries in achieving sustainable development.
Though it lacks a precise definition, sustainable development is generally considered to include
principles of intergenerational equity and sustainable use. Burning coal is one of the major
sources of greenhouse gas emissions that must be curbed for the protection of future
generations, and it can not seriously be considered a sustainable use practice.
Relieving European power giant RWE Power and its home country of Germany of obligations to
reduce domestic emissions reductions by helping build a new coal-fired power plant in China is
either an abuse of the Kyoto flexibility mechanisms and a call for substantial reform and
redirection, or an illustration of the corruption of the carbon market concept as a whole.
I. Additionality
The additionality of the Zhejiang project is not credible and the PDD does not include the
information and documentation required by the rules to support the assertion of additionality.
Without the required evidentiary documentation, the DOE must find that the project is not
additional.
a) No evidence of prior consideration of CDM
The timeline for the development projects raises serious questions about the consideration of
CDM in the decision to proceed with the project, which leaves an additionality determination very
dubious. Table B.5-1 of the PDD indicates that the project investment decision was made on
November 3, 2005; the main purchase agreement was signed on March 22, 2006; construction
formally started on December 15, 2006; and the first unit of the project operated on December 20,
2008. While the table asserts that CDM participation was part of the initial investment decision,
there is no reference to any documentation to support this important assertion. If the assertion is
untrue, or if it can not be supported, then the project is not additional.
The Zhejiang PDD includes no documentation or reference to any evidence to support the
assertion that consideration of CDM was part of the 2005 project investment decision. Where are
the minutes or notes related to the consideration of the investment decision of the Guodian
Zhejiang Beilun Third Power Generation Co., Ltd. to undertake the project as a CDM activity?
Also, to determine whether there were “continuing and real actions were taken to secure CDM
status for the project in parallel with its implementation,” the DOE must focus on “real
documented evidence” and an assessment of the authenticity of such evidence. The PDD
neither includes nor references any real documented evidence.
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Due to the lack of evidence, the DOE must determine that the CDM was not considered in the
decision to implement the project activity and the project is not additional.
b. Inadequate alternatives analysis/baseline setting
The alternatives analysis (PDD section B.4.) used to set the baseline and determine additionality
is also faulty. First, the references for the discussion of the identified alternatives are inadequate.
According to the PDD guidance, this section is to “Explain and justify key assumptions and
rationales. Provide relevant documentation or references. Illustrate in a transparent manner all
data used to determine the baseline scenario (variables, parameters, data sources, etc.).” EB 41
Report Annex 12 p. 11. The rationales for the elimination from consideration of the more
sustainable energy sources, hydro and wind, biomass, and MSW incineration (alternatives 7 and
8) are not adequately supported. In particular, nuclear power should be identified as a plausible
alternative scenario in page 9 table B.4-1. Nuclear plants represent a small but still significant
contribution to the most recent builds identified in the grid analysis and would provide equivalent
baseload generation, albeit with no CO2 emissions. Just because they can't be a CDM project
does not mean that they should not be considered as potential build alternatives in a baseline
analysis.
c. Faulty and unsupported investment analysis
The investment analysis portion of the additionality analysis is also inadequate. First, the
investment analysis includes no spreadsheets and is not reproducible or transparent.
In addition, the Annex: Guidance on the Assessment of Investment Analysis to the Addtionality
Tool requires that the fair value of the project assets at the end of the assessment period should
be included as a cash inflow in the final year of the project. The fair value of the project assets at
the end of the assessment period does not appear to have been included in the investment
analysis.
d. Project fails common practice analysis
According to the PDD, there are three other 1000MW ultra-supercritical power plants that have
begun operations since 2006. Although these all are reportedly attempting to obtain CDM
validation, it seems that none has. That there are three other plants using the same technology
and all have been build without receiving any CDM funding (as has the project under review), the
indication is that the use of the project technology and the project activity do constitute current
common practice.
e. Calculation of emissions reductions
Leakage is the net change of anthropogenic emissions by sources of greenhouse gases which
occurs outside the project boundary, and which is measurable and attributable to the CDM project
activity. Leakage must be accounted for in the estimation of emissions reductions.
The PDD admits to zero leakage. It should consider the emissions resulting from the project
outside its temporal boundaries. What amount of greenhouse gases will be emitted by the project
after the end of the crediting period in 2019? This project is to construct a brand new coal-fired
power plant. Absent a non-existent commitment from the project owners to shut down the plant
at the end of the project period, the plant will continue to emit substantial volumes of greenhouse
gases for years to come. What is the expected operational life of this plant? How much will it
emit over its lifetime? How does the emissions reduction calculation account for this?
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f. Construction
Presumably, the construction of the project was a somewhat major project that generated
greenhouse gas emissions both at the construction site and offsite, in the production and
transportation of equipment and materials. These emissions appear to be excluded from the
PDD’s estimation of emissions reductions.
II. Public Participation
The information in the PDD is insufficient to show that the project developer conducted an
appropriate and adequate public participation process. To the contrary, the information provided
indicates that the public participation process fails to satisfy the requirements of UNFCCC Article
6. to ”[p]romote and cooperate in education, training and public awareness related to climate
change and encourage the widest participation in this process, including that of nongovernmental
organizations.” Public participation is a key to achieving the sustainable
development goal of the CDM. However, this requirement has not been taken into account
seriously:
• Section E of the Zhejiang PDD includes sections on the questionnaire and consultation
meeting that apparently consisted of the entirety of the public participation process. The PDD
reports that 92 questionnaires were distributed and all of them were returned and expressed
support for the project. The 100% return and support rates raise questions about the
selection of the respondents and whether the questionnaire results truly reflect public opinion
about the project. It seems unlikely that 100% of questionnaires distributed randomly or
sufficiently widely would be returned and even less likely that a widely or randomly or
representatively distributed survey would find 100% project support. To whom were the 92
questionnaires given? The PDD guidelines call for identification of these people, yet none is
included here. Were these people selected or picked at random? Were questionnaires
provided to a wide range of people with varying interests? Was an opportunity provided to
anyone who wanted to have a say, or only to those persons selected? The questionnaire
collected “general information of the respondent” – what does this information indicate about
who was asked for their opinions?
• The questions on the questionnaire also seem crafted to solicit the maximum project support.
They appear designed to prompt expressions of desire for economic development and not to
prompt consideration of environmental concerns.
• The “consultation meeting” consisted of twenty participants, again unnamed, and, again,
100% in support of the project. The twenty participants included “officer representatives,
enterprises’ representatives, local dwellers and CDM consultant institute of the Project etc.”
Exactly how many actual local residents or community leaders were included in this meeting?
The presence of several representatives of entities directly engaged in the project
development in such a small meeting is likely to have discouraged any serious or hard
questioning or criticism of the project. That the PDD summarily states that “the Project owner
and CDM consultant institute collected earnestly the participants’ comments and
suggestions” is a self-serving statement that fails to demonstrate that there was adequate
and meaningful solicitation of public input.
• The PDD does identify that some questionnaire respondents identified concerns about air
pollution. However, there is no substantive discussion whatsoever about the air pollution
concerns of local area residents.
• PDD section E.3. concerning the report on how due account was taken of any comments
received is also a self-serving conclusory statement. How did the Project owner take into
careful consideration the unspecified “public worries about possible environmental impacts
incurred by the Project”? What are the environmental measures that will be taken? Do these
measures satisfy the concerns of the public?
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The DOE should deny validation of this project because – contrary to the rules and the guidelines
– the PDD fails to demonstrate that a public process that satisfies the intent of the Modalities and
UNFCCC Article 6 was conducted. Indeed, the information in the PDD tends to indicate that the
public process was a sham, including only a small number of people, if any, without a vested
interest in the project, all of whom supported the project, and that nothing has been done to
explore and take into account the pollution concerns of area residents.

Such Pollution Development Mechanisms in the name of CDM is not to e allowed. This is creating a trend were in countries like India and China such projects which not only pollutes and adds to climate change but also result in commiting human rights and environmental viloations in the host country as well. UNFCC should nto legitimise such interventions in the name of CDM

CDM ultra-super critical coal project in China by RWE-Europe's biggest polluter-does not show us bright rays; rather this obstructs carbon free future and avenues to sustainable development

I wish to raise concerns regarding this project. We do not believe it is consistent with the sustainable development goals of the CDM. 

Insufficient evidence is provided to show that the CDM formed part of the initial investment assessment and decision.

The project technology and project activity are already common practice since three such projects were all commissioned before 2006 with none of them receiving CDM funding.

Lifetime emissions after the end of the project crediting period are not accounted for in the estimation of emissions reductions and emissions from construction are not included.

We also have concerns over the degree of public involvement in the project particularly in relation to environmental and air pollution concerns.